Mauritius vs Saudi Arabia
Crypto regulation comparison
Mauritius
Saudi Arabia
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.
Saudi Arabia has an ambiguous but generally restrictive approach to cryptocurrency. SAMA has not licensed any crypto exchanges, and financial institutions are warned against dealing in crypto. However, crypto is not explicitly banned by law, and Saudi Arabia has participated in blockchain initiatives (Project Aber with the UAE central bank). No personal income or capital gains tax exists in Saudi Arabia.
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
- SAMA has not authorized or licensed any cryptocurrency exchanges
- Financial institutions warned against crypto transactions
- Crypto not explicitly banned but not regulated; exists in a legal gray area
- No personal income or capital gains tax in Saudi Arabia
- Saudi Arabia participated in CBDC experiments (Project Aber with UAE)