Liechtenstein vs Mauritius
Crypto regulation comparison
Liechtenstein
Mauritius
Liechtenstein's Blockchain Act (TVTG) effective since 2020 is among the world's most comprehensive crypto frameworks. The FMA supervises registered TT service providers. Adapted for EU MiCAR in 2025.
Mauritius has developed a regulatory framework for virtual assets through the Financial Services Commission. The Virtual Asset and Initial Token Offering Services Act 2021 (VAITOS Act) provides licensing for VASPs. Mauritius positions itself as a fintech-friendly jurisdiction in Africa with a flat 15% income tax rate applicable to crypto income.
Key Points
- Blockchain Act (TVTG) adopted unanimously in 2019, effective Jan 2020
- Token Container Model enables tokenization of any asset or right
- FMA registers and supervises all TT service providers
- EEA MiCAR Implementation Act entered into force Feb 2025
- First country with comprehensive blockchain-specific legislation
Key Points
- VAITOS Act 2021 provides comprehensive licensing for VASPs
- FSC issues Class M (custodian), Class O (exchange), Class R (advisory) licenses
- Flat 15% income tax rate applies to crypto income
- No separate capital gains tax; gains may be treated as income
- Mauritius is a member of FATF and complies with international AML standards