Mauritius vs Netherlands
Crypto regulation comparison
Mauritius
Netherlands
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.
The Netherlands has one of Europe's strictest crypto regulatory regimes. DNB has overseen VASP registration since 2020 under the Dutch AML/CFT Act (Wwft), and many applications have been rejected. The Netherlands does not tax realized capital gains directly; instead, crypto holdings are taxed under the Box 3 wealth tax based on a deemed return on net assets. The AFM oversees market conduct. MiCA is now the governing framework.
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
Key Points
- DNB requires VASP registration under the Wwft (AML Act); rigorous approval process
- Only a limited number of VASPs have obtained DNB registration (many rejected or withdrawn)
- Crypto taxed under Box 3 wealth tax: deemed return on net assets taxed at ~31-36% (effective ~1.2-1.6%)
- AFM regulates crypto advertising and market conduct; banned crypto ads targeting retail in 2022
- MiCA framework applicable from December 2024, transitioning from national DNB regime