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Philippines vs United States

Crypto regulation comparison

Philippines

Philippines

United States

United States

Legal
Legal

The Philippines is one of the largest crypto markets in Southeast Asia. The BSP licenses Virtual Asset Service Providers (VASPs) under Circular 1108 (2021), and the SEC regulates crypto as securities where applicable. The Philippines saw massive adoption through play-to-earn games (Axie Infinity) and remittances. Crypto income is taxed at progressive income tax rates.

The United States has the world's most complex crypto regulatory landscape, with overlapping federal and state jurisdictions. The SEC regulates crypto securities and has pursued enforcement actions against exchanges and token issuers. The CFTC oversees crypto derivatives and considers Bitcoin a commodity. FinCEN applies BSA requirements to crypto exchanges as money service businesses. The IRS taxes crypto as property: short-term gains at income tax rates (10-37%), long-term gains at 0-20%. New 1099-DA broker reporting rules take effect from 2025. Multiple states have their own requirements, with New York's BitLicense being the most stringent.

Tax Type Income
Tax Type Capital gains
Tax Rate 0-35%
Tax Rate 0-37%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator BSP (Bangko Sentral ng Pilipinas), SEC Philippines
Regulator SEC, CFTC, FinCEN, OCC, IRS, State regulators
Stablecoin Rules BSP regulates virtual asset service providers including stablecoin operations
Stablecoin Rules Stablecoin legislation actively being developed in Congress; existing oversight by SEC, CFTC, state regulators
Key Points
  • BSP Circular 1108 (2021) provides comprehensive VASP licensing framework
  • BSP has licensed major exchanges including Coins.ph and PDAX
  • SEC Philippines regulates crypto securities and has issued warnings on unregistered offerings
  • Crypto income taxed at progressive rates (0-35%); 12% VAT may apply to exchanges
  • Play-to-earn gaming (Axie Infinity) drove massive adoption, especially in rural areas
Key Points
  • SEC regulates crypto as securities under Howey test; major enforcement actions (Ripple, Coinbase, Binance)
  • CFTC classifies Bitcoin and Ether as commodities; oversees derivatives markets
  • IRS treats crypto as property: short-term gains taxed at 10-37%, long-term (1yr+) at 0-20%
  • FinCEN requires exchanges to register as MSBs and comply with BSA/AML requirements
  • 1099-DA broker reporting for centralized exchanges effective from tax year 2025