1. United States
Legal Status:
- Cryptocurrencies are legal.
- The SEC, CFTC, IRS, and FinCEN have overlapping regulatory authority.
- Ongoing legal debates over whether crypto tokens are securities or commodities.
Taxation:
- Treated as property by the IRS.
- Subject to capital gains tax on profits from selling, exchanging, or using crypto.
Regulatory Environment:
- KYC/AML required.
- SEC has cracked down on unregistered securities (e.g., Ripple/XRP).
- Stablecoin regulation and crypto exchange oversight are being debated in Congress.
2. European Union
Legal Status:
- Crypto is legal across the EU.
- The Markets in Crypto-Assets Regulation (MiCA) law passed in 2023, providing a unified legal framework.
Taxation:
- Member states have varying tax rules (e.g., Germany exempts crypto held over 1 year from tax).
Regulatory Environment:
- MiCA focuses on stablecoins, exchanges, token issuers, and consumer protection.
- Mandatory licensing and disclosure rules are rolling out.
3. United Kingdom
Legal Status:
- Cryptocurrencies are legal and recognized as property.
- The FCA regulates crypto-related firms under anti-money laundering rules.
Taxation:
- Capital gains tax applies to crypto profits.
- Trading as a business may result in income tax.
Regulatory Environment:
- Stablecoins may soon be regulated under UK’s Electronic Money Regulations.
- Stricter rules for crypto advertisements and promotions in 2023.
4. China
Legal Status:
- All cryptocurrency trading and mining are banned.
- The government promotes blockchain development (e.g., BSN – Blockchain Service Network).
Taxation:
- No clear crypto taxation due to the ban.
Regulatory Environment:
- Strong support for central bank digital currency (CBDC) – the digital yuan.
- Blockchain used for state-led applications (e.g., supply chain, smart city tech).
5. India
Legal Status:
- Crypto is not banned, but not considered legal tender.
- Government is exploring full legislation and possibly launching its own CBDC.
Taxation:
- Flat 30% tax on crypto gains, plus 1% TDS (tax deducted at source) on all transactions.
Regulatory Environment:
- No clear regulatory framework yet.
- RBI is cautious and has discouraged banks from working with crypto companies, although the Supreme Court lifted an earlier ban.
6. Japan
Legal Status:
- Crypto is legal and considered a legal method of payment under the Payment Services Act.
- Highly regulated, with clear laws on exchanges and custodians.
Taxation:
- Crypto gains are considered miscellaneous income and taxed at up to 55% depending on income bracket.
Regulatory Environment:
- Japan is a global leader in crypto regulation.
- Licensing required for all crypto exchanges.
- AML and KYC enforced strictly by the Financial Services Agency (FSA).
7. South Korea
Legal Status:
- Cryptocurrencies are legal.
- Strong regulation over exchanges and token issuance.
Taxation:
- A 20% tax on crypto gains over ₩2.5 million is expected to be enforced in 2025.
Regulatory Environment:
- Exchanges must follow strict AML and KYC laws.
- The Act on Reporting and Use of Specified Financial Transaction Information requires exchange registration.
8. Singapore
Legal Status:
- Cryptocurrencies are legal and regulated under the Payment Services Act (PSA).
Taxation:
- No capital gains tax.
- Income from trading or business use may be taxed as income tax.
Regulatory Environment:
- The Monetary Authority of Singapore (MAS) licenses crypto exchanges.
- Focused on being a crypto-friendly hub while ensuring strong AML/KYC enforcement.
9. United Arab Emirates (UAE)
Legal Status:
- Crypto is legal in free zones like Dubai (VARA) and Abu Dhabi (ADGM).
- Regulation is progressive and pro-innovation.
Taxation:
- No personal income tax; corporate tax introduced in 2023, with exemptions for many crypto activities.
Regulatory Environment:
- Dubai has a dedicated Virtual Assets Regulatory Authority (VARA).
- Emirates aim to become a global blockchain innovation center.
10. Australia
Legal Status:
- Cryptocurrencies are legal and treated as property.
- Exchanges must register with AUSTRAC for AML/KYC compliance.
Taxation:
- Capital gains tax applies.
- Business use may attract income tax or GST obligations.
Regulatory Environment:
- Ongoing consultations to establish clearer rules.
- ASIC is monitoring crypto investment products and scams.
11. Canada
Legal Status:
- Crypto is legal, considered a commodity by regulators.
- Exchanges must register with FINTRAC.
Taxation:
- Capital gains or business income tax, depending on usage.
Regulatory Environment:
- Securities laws apply to many crypto assets.
- Stricter requirements introduced for custody, staking, and leverage on exchanges.
12. Brazil
Legal Status:
- Crypto is legal but not legal tender.
- Law passed in 2022 to recognize digital assets and establish regulatory guidelines.
Taxation:
- Capital gains above R$35,000/month are taxed.
- Reporting requirements for crypto holdings apply.
Regulatory Environment:
- Central Bank regulates exchanges and promotes CBDC pilot.
- Tax authority requires detailed crypto asset reporting.
13. Russia
Legal Status:
- Crypto is legal, but not for payments.
- Government supports mining and blockchain use for state services.
Taxation:
- Gains are taxable under capital gains rules.
Regulatory Environment:
- Legal framework restricts crypto for daily transactions.
- Development of a digital ruble is in progress.
Summary Chart
| Country | Legal Status | Taxation | Regulator/Framework |
|---|---|---|---|
| USA | Legal | Capital gains | SEC, CFTC, IRS, FinCEN |
| EU | Legal | Varies by country | MiCA (from 2024) |
| UK | Legal | Capital gains | FCA |
| China | Banned (crypto) | N/A | CBDC & blockchain R&D supported |
| India | Legal (restricted) | 30% gains tax, 1% TDS | Pending legislation |
| Japan | Legal | Up to 55% income tax | FSA |
| South Korea | Legal | 20% gains tax (from 2025) | FSC, AML laws |
| Singapore | Legal | No CGT | MAS |
| UAE | Legal (zones) | No personal tax | VARA, ADGM |
| Australia | Legal | CGT & business tax | AUSTRAC, ATO |
| Canada | Legal | Capital gains/income tax | FINTRAC |
| Brazil | Legal | CGT above threshold | Receita Federal, Central Bank |
| Russia | Legal (not tender) | Taxable | Central Bank, pending crypto bill |