Netherlands vs San Marino
Crypto regulation comparison
Netherlands
San Marino
Legal
Legal
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.
San Marino has developed a regulatory framework for blockchain entities. The country has issued licenses for blockchain-based businesses.
Tax Type
Wealth
Tax Type
Unclear
Tax Rate
~1.2-1.6% (deemed return)
Tax Rate
N/A
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
DNB (De Nederlandsche Bank), AFM (Autoriteit Financiële Markten)
Regulator
Central Bank of San Marino, AIF (Financial Information Agency)
Stablecoin Rules
Regulated under EU MiCA framework; DNB oversight
Stablecoin Rules
No specific stablecoin regulation
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- Only a limited number of VASPs have obtained DNB registration (many rejected or withdrawn)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
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