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Netherlands vs El Salvador

Crypto regulation comparison

Netherlands

Netherlands

El Salvador

El Salvador

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.

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199), El Salvador amended the law to make Bitcoin acceptance by businesses voluntary rather than mandatory, and repealed several articles.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 Wealth
Tax Type No tax
Tax Rate ~1.2-1.6% (deemed return)
Tax Rate 0%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator DNB (De Nederlandsche Bank), AFM (Autoriteit Financiële Markten)
Regulator BCR (Banco Central de Reserva), CNAD (Comisión Nacional de Activos Digitales)
Stablecoin Rules Regulated under EU MiCA framework; DNB oversight
Stablecoin Rules USD is the primary currency; Bitcoin-specific legislation in place
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  • Only a limited number of VASPs have obtained DNB registration (many rejected or withdrawn)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
  • 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