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Mauritius vs El Salvador

Crypto regulation comparison

Mauritius

Mauritius

El Salvador

El Salvador

Legal
Legal

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.

El Salvador made history in September 2021 by becoming the first country to adopt Bitcoin as legal tender through the Bitcoin Law. However, under a January 2025 IMF agreement (Decreto 199), El Salvador amended the law to make Bitcoin acceptance by businesses voluntary rather than mandatory, and repealed several articles. There is no capital gains tax on Bitcoin. The CNAD regulates digital assets.

Tax Type Income
Tax Type No tax
Tax Rate 15%
Tax Rate 0%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FSC (Financial Services Commission)
Regulator BCR (Banco Central de Reserva), CNAD (Comisión Nacional de Activos Digitales)
Stablecoin Rules Virtual assets regulated under FSC framework
Stablecoin Rules USD is the primary currency; Bitcoin-specific legislation in place
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
  • First country to adopt Bitcoin as legal tender in September 2021 via the Bitcoin Law
  • Government developed the Chivo wallet for citizens, offering $30 USD in BTC incentive
  • January 2025 Decreto 199 made merchant Bitcoin acceptance voluntary (IMF condition)
  • No capital gains tax on Bitcoin transactions for individuals
  • Government has been accumulating Bitcoin reserves and launched Bitcoin-backed bonds