Mauritius vs Panama
Crypto regulation comparison
Mauritius
Panama
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.
Panama passed Law 129 in 2024 regulating crypto assets, virtual asset service providers, and tokenized securities. Panama has no capital gains tax on foreign-sourced or investment income, making it attractive for crypto investors. The law provides a regulatory framework for exchanges and establishes AML/KYC obligations for VASPs.
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
- Law 129 (2024) regulates crypto assets and VASPs in Panama
- No capital gains tax on investment or foreign-sourced income (territorial tax system)
- VASPs must comply with AML/KYC requirements under the new framework
- Crypto payments for commercial transactions are permitted
- Panama's territorial tax system means crypto gains from international trading are untaxed