In the United States, regulators are moving towards a national framework rather than relying on case-by-case rules. The GENIUS Act has already been signed into law, while other measures, including the Clarity Act and the CBDC Surveillance Act, are still in progress. Crypto exchange-traded funds (ETFs) are also gaining traction, with record trading volumes.
Canada classifies crypto investment firms as money service businesses, and digital assets are taxed like commodities. Several ETFs not yet available in the US are already trading in Canada.
According to Sanjay Kathuria, crypto can form part of an investment portfolio, but only in small measure, highlighting the need for cautious participation.
The United Kingdom began regulating crypto in 2020 and is developing a broader framework expected to take effect in 2026. Switzerland has a structured approach, taxing crypto holdings under income and wealth regulations.
El Salvador made history in 2021 as the first country to declare Bitcoin legal tender, exempting foreign investors from tax on Bitcoin income. Singapore licenses exchanges and wallet providers under its Payment Services Act of 2019.
The European Union adopted its first unified crypto rules in 2023 under the Markets in Crypto Assets (MiCA) framework, focusing on investor protection and financial stability.
Japan plans to launch a yen-pegged stablecoin in 2025. China, despite restrictions, is exploring a privately issued yuan stablecoin alongside its digital yuan. Hong Kong introduced stablecoin regulation on August 1 this year.
Pakistan has set up a Crypto Council and plans to build a Bitcoin reserve. Bhutan allows visitors to use cryptocurrencies for goods, services, and travel expenses, making it one of the most crypto-accessible countries.
In India, a national framework is still pending. Cryptocurrencies are classified as virtual digital assets under Section 224A of the Income Tax Act, with gains taxed at 30% plus 1% TDS on transactions.
For investors, experts caution that while global adoption grows, exposure to crypto should remain measured.
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