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Liechtenstein vs San Marino

Crypto regulation comparison

Liechtenstein

Liechtenstein

San Marino

San Marino

Legal
Legal

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.

San Marino has developed a regulatory framework for blockchain entities. The country has issued licenses for blockchain-based businesses.

Tax Type Income
Tax Type Unclear
Tax Rate 1-8%
Tax Rate N/A
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator Financial Market Authority (FMA)
Regulator Central Bank of San Marino, AIF (Financial Information Agency)
Stablecoin Rules Regulated under TVTG and MiCAR
Stablecoin Rules No specific stablecoin regulation
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
  • Delegated Decree on blockchain technology entities issued
  • Licenses issued for blockchain-based businesses
  • AIF provides regulatory oversight
  • Small jurisdiction working to attract blockchain companies
  • Developing comprehensive digital asset regulation