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5 leading crypto jurisdictions alternative to MiCA in 2026

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5 leading crypto jurisdictions alternative to MiCA in 2026

Disclosure: This article does not represent investment advice. The content and materials featured on this page are for educational purposes only.

MiCA delivers certainty in Europe, but rising compliance costs are pushing many crypto firms to explore flexible offshore licensing in 2026.

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Summary

  • MiCA brings EU certainty, but firms eye mid-shore hubs for flexibility, tax efficiency, and faster crypto market entry.
  • Dubai, Canada, and BVI have emerged as alternatives to MiCA, offering lower costs and specialized compliance paths.
  • LegalBison helps crypto firms navigate global licensing as businesses diversify beyond single-jurisdiction MiCA models.

The implementation of the MiCA regulation has undeniably brought a high degree of certainty to the European market. However, for many Crypto Asset Service Providers (CASPs), the trade-off such as high capital requirements, strict physical substance rules, and intensive reporting can be a barrier to entry. 

In 2026, the global landscape offers several “mid-shore” and offshore alternatives that provide agility, tax efficiency, and robust legal frameworks without the specific constraints of an EU crypto license.

Whether someone is looking for a rapid market entry, specialized activity-based rules, or a tax-neutral home for their treasury, these jurisdictions represent the strongest alternatives to MiCA compliance.

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1. Dubai (VARA): The specialized global hub

For those looking for a jurisdiction that treats crypto as its primary focus rather than an add-on to traditional finance, the Dubai VARA crypto license is the premier choice for 2026.

Why Choose Dubai VARA?

  • Activity-Specific Rulebooks: Unlike the broader MiCA framework, VARA provides tailored rulebooks for specific activities like custody, exchange, and broker-dealer services. This allows for more precise operational planning.
  • Tax Neutrality: Dubai remains one of the most tax-efficient hubs in the world, offering 0% corporate tax for qualifying activities in many free zones.
  • Speed and Innovation: The application process is generally more interactive and faster than the typical 12-month wait for an EU crypto license.

For firms targeting the MENA region and institutional capital, the Dubai VARA crypto license offers a level of prestige that rivals any European regulator.

2. Canada: The low-barrier gateway to North America

For startups that prioritize speed and cost-effectiveness, the Canada crypto license with MSB (Money Services Business) registration is often the fastest route to a reputable Western license.

The Canadian Advantage

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  • No Minimum Capital: Unlike MiCA, which requires up to €150,000 in Tier 1 capital, Canada has no fixed minimum capital requirement for MSB registration.
  • Rapid Onboarding: Registration with FINTRAC can often be completed in 3 to 5 months, making it significantly faster than pursuing a Poland crypto license or CASP license in Malta.
  • FMSB Option: Canada allows for “Foreign Money Services Business” status, enabling some firms to operate without a full-scale physical headquarters in the country.

3. The British Virgin Islands (BVI): The professional offshore choice

The BVI crypto license (under the VASP Act) has become the gold standard for token issuers and DeFi protocols that require a tax-neutral environment.

Why the BVI?

  • Zero Tax: 0% corporate tax, 0% capital gains tax, and no withholding tax on dividends.
  • Legal Stability: Based on English Common Law, the BVI offers a highly predictable legal environment that investors and VCs trust.
  • Flexibility for Token Issuers: For those issuing a MiCA-compliant token, the BVI offers a compelling “Plan B” with far fewer restrictions on how token generation events (TGEs) are structured.

Asia’s Emerging Titans: Hong Kong and Singapore

For firms looking to tap into the world’s most active retail and institutional trading markets, securing a crypto license in Asia is a strategic necessity.

4. Hong Kong (SFC)

By 2026, Hong Kong has fully opened its doors to retail trading. It provides a stable, highly regulated environment that serves as the primary bridge to liquidity from Mainland China.

5. Singapore (MAS)

While the MAS is known for its rigorous standards, a Singaporean license is essentially a “seal of quality.” It is the preferred choice for major payment institutions (MPI) that want to combine crypto services with traditional fiat processing.

Strategic comparison: 2026 crypto licensing landscape

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Jurisdiction Primary License Timeline Min. Capital Tax Profile
Dubai VARA License 4-7 Months ~$50k-$150k 0% – 9%
Canada MSB Registration 3-5 Months Varies ~15% – 27%
BVI VASP License 4-6 Months Varies 0%
EU (e.g. CZ) Czech Republic CASP license 6-12 Months €50k – €150k 19% – 21%

Global expansion with LegalBison

Choosing a jurisdiction is the most consequential decision a founder can make. LegalBison is a leading legal firm specializing in global company formation and crypto licensing. 

By providing end-to-end support from initial feasibility studies to the final submission of an application; LegalBison ensures that a business is structurally sound and compliant with local regulators, whether it’s targeting the Middle East, the Americas, or Asia.

Diversification is the new compliance

In 2026, the most successful crypto businesses are rarely “single-jurisdiction” entities. While MiCA compliance provides a massive market, alternative hubs like Dubai, Canada, and the BVI offer specialized advantages that can significantly lower your operational burn rate.

By working with a dedicated partner like LegalBison, businesses can ensure that their choice of jurisdiction aligns with their long-term roadmap, whether that includes issuing a MiCA-compliant token or expanding footprint across the Asia-Pacific region.

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Crypto World

Dutch House of Representatives Advances Controversial 36% Tax Law

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Crypto Breaking News

The Netherlands’ lower chamber moved a sweeping capital-gains plan forward on Thursday, proposing a 36% tax on savings and most liquid assets, including cryptocurrencies. The bill cleared the House of Representatives with 93 lawmakers voting in favor, meeting and surpassing the threshold of 75 required to advance the measure. It would apply regardless of whether the assets are sold, extending to savings accounts, crypto holdings, most equity investments and gains from interest-bearing instruments. If the Senate signs off, the policy would take effect in the 2028 tax year. Critics argue the plan risks driving capital out of the Netherlands as investors seek jurisdictions with more favorable tax conditions. The discussion comes amid a broader global conversation about crypto taxation and how unrealized gains should be treated for high-net-worth and retail investors alike. The Dutch tally, published by the House, confirms the legislative momentum behind the proposal.

Key takeaways

  • The bill would impose a 36% capital-gains tax on savings and most liquid investments, explicitly including cryptocurrencies, with the tax levied even if assets are not disposed of.
  • The measure advanced after a 93-to-what-it-took vote in the Dutch House, surpassing the 75-vote threshold to proceed, signaling strong political alignment in favor of the reform.
  • Enactment hinges on Senate approval; if passed, the policy would apply beginning with the 2028 tax year, giving policymakers and investors time to prepare for the transition and for further details to emerge on implementation.
  • Critics warn the proposal could trigger capital flight from the Netherlands to jurisdictions with lower tax burdens, drawing on historical examples where similar levies spurred relocation of entrepreneurship and investment activity.
  • Analysts and industry figures have offered stark projections about the long-term impact on wealth accumulation, including widely cited calculations showing substantial reductions in compound growth under an unrealized-gains tax regime; comparisons to other tax debates in major markets underscore the broader risk environment for crypto and tech capital.

Tickers mentioned:

Sentiment: Bearish

Market context: The Netherlands’ proposal sits within a wider European and global dialogue on crypto taxation, where authorities weigh revenue needs against innovation incentives. As tax authorities assess how unrealized gains should be treated, the Dutch plan adds to considerations around how digital-asset holdings are accounted for in personal and investment taxation, echoing debates across the EU about consistency, enforcement, and the boundaries of capital taxation in a digital era.

Why it matters

The central premise — taxing unrealized gains on a broad swath of assets, including cryptocurrencies — marks a notable shift in how governments might approach wealth and investment in an era of rapid digital-asset adoption. Proponents argue that a real-time tax on gains helps address perceived inequities in how passive wealth is taxed versus earned income, potentially increasing public revenue to fund social and infrastructure initiatives. Yet, the immediate reaction from market participants and crypto executives has been skeptical, raising concerns about distortions to investment decisions and the long-run competitiveness of the Netherlands as a home for startups and asset management.

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Analysts highlighted the unintended consequences of such a policy. Denis Payre, co-founder of logistics firm Kiala, invoked a historical parallel, noting that France’s experience with an earlier capital-sweep proposal led to a pronounced exodus of entrepreneurs. The sentiment among several industry observers echoed this caution, with crypto market analyst Michaël van de Poppe describing the proposal as counterproductive and predicting a material shift of capital to more favorable environments. The underlying critique is that high tax rates on unrealized gains could dampen risk appetite and deter early-stage capital formation, especially for innovative sectors where growth often hinges on reinvested profits rather than realized gains.

Beyond the Netherlands, the broader economic calculus is clear: tax policy can have a measurable impact on how wealth compounds over decades. For instance, a widely cited hypothetical scenario contrasts outcomes with and without unrealized-gains taxation. Starting with 10,000 euros and contributing 1,000 euros monthly for 40 years, one study suggested the pre-tax outcome might reach around 3.32 million euros, whereas applying a 36% unrealized gains tax would reduce the final tally to roughly 1.89 million euros, a gap of about 1.435 million euros. While such projections depend on many assumptions, they illustrate how timing and recognition of gains influence long-term wealth accumulation, particularly for asset classes that can experience both rapid appreciation and volatility.

The policy also lands in the context of a U.S. debate around wealth taxes and crypto regulation. California, for example, has faced controversy over proposals to impose wealth taxes on billionaires, sparking a broader discourse about the balance between tax fairness and the incentives for innovation. While the Dutch measure focuses on unrealized gains across a wide array of assets, the parallel debates illustrate a growing global sensitivity to how digital assets are taxed and how such tax rules interact with entrepreneurship and capital formation.

As investors digest these signals, the crypto community has echoed concerns about the practicalities of enforcing a 36% rate on assets that can be volatile and illiquid, and about how such taxation affects portfolio strategies, cross-border activity, and the flow of capital to jurisdictions deemed more crypto-friendly. The discussion points to a broader trend where policymakers are still navigating the line between revenue-generation aims and the need to sustain a supportive environment for innovation and decentralized finance.

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What to watch next

  • Whether the Dutch Senate approves the bill and whether amendments alter the scope or rate of the proposed tax.
  • How the government and tax authorities define and enforce unrealized gains on a diverse set of assets, including cryptocurrencies.
  • Potential investor behavior in response to the policy, including any observed shifts to foreign domiciliation or cross-border holdings.
  • Any forthcoming data or studies assessing the macroeconomic impact of the reform on investment, entrepreneurship, and innovation in the Netherlands.
  • Broader EU considerations on crypto taxation and cross-border consistency as other member states weigh similar approaches.

Sources & verification

  • Tweep: Dutch House tally page showing the vote threshold and tally details for the bill (dossier 36748; id 2025Z09723). Verify the official tally and the threshold requirement here: https://www.tweedekamer.nl/kamerstukken/wetsvoorstellen/detail?dossier=36748&id=2025Z09723#wetgevingsproces
  • Investing Visuals projection comparing compound growth with and without unrealized gains tax over 40 years. See the analysis referenced in coverage of the proposal’s long-term effects: https://x.com/InvestingVisual/status/2022221938840441335
  • Statements from Denis Payre on the potential capital flight risk associated with such a tax proposal: https://x.com/DenisPayre/status/2022… (X post linked in coverage)
  • Commentary from Michaël van de Poppe critiquing the plan: https://x.com/CryptoMichNL/status/2022209120322121928
  • California’s wealth-tax discussion as a comparative reference in crypto regulation debates: https://cointelegraph.com/news/california-billionaire-tax-crypto-executives-slam

Netherlands advances 36% capital gains tax on savings and crypto

The House of Representatives’ decision to push the 36% capital gains tax proposal forward marks a pivotal moment in how the Netherlands could tax a broad spectrum of wealth. The measure targets not only traditional savings but also a wide range of liquid assets, explicitly including crypto assets, and would tax gains even when assets remain unrealized. The bill’s fate now rests with the Senate, and the clock is set for a 2028 effective date should the upper chamber approve the legislation in its final form. The political calculus surrounding this proposal underscores a broader concern among investors and industry observers: will such a tax regime dampen the country’s appeal as a hub for crypto and tech entrepreneurship, or can it be calibrated in a way that sustains public revenue without stifling innovation?

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Netherlands Lower Chamber Passes 36% Tax Proposal Before Passing to Senate

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Taxes, Netherlands, Bitcoin Regulation

The Netherlands’ House of Representatives advanced a legislative proposal on Thursday to introduce a 36% capital gains tax on savings and most liquid investments, including cryptocurrencies.

The legislation reached the 75-vote threshold required to advance, with 93 lawmakers voting in favor of it, according to the House tally.

Under the proposal, savings accounts, cryptocurrencies, most equity investments and gains made from interest-bearing financial instruments are subject to the tax, whether or not the assets are sold.

Taxes, Netherlands, Bitcoin Regulation
The vote tally for the 36% capital gains tax bill. Source: Dutch House of Representatives

Critics say the bill will drive capital out of the Netherlands and into jurisdictions with more favorable tax laws, as investors seek a flight to safety from confiscatory taxation.

The Dutch Senate must also pass the bill before it is signed into law, which will take effect in the 2028 tax year, if it is passed, but many investors in the crypto community are already sounding the alarm and predicting capital flight from the country.

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Related: European Commission calls on 12 countries to implement crypto tax rules

Investors say the tax is out of touch and will backfire

“France did this in 1997 and saw a massive exodus of entrepreneurs leaving the country,” Denis Payre, co-founder of logistics company Kiala said.

Crypto market analyst Michaël van de Poppe said the proposal is “the dumbest thing I’ve seen in a long time.”

“The number of people willing to flee the country is going to be bananas,” he added, echoing the calls of other industry analysts and executives.

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An investor starting with 10,000 euros ($11,871) who contributes 1,000 euros per month over 40 years would end up with about 3,320,000 euros by the end of the 40 years, according to Investing Visuals.

However, the new 36% tax reduces the total amount after 40 years to about 1,885,000 euros, a difference of 1,435,000 euros, Investing Visuals said. 

Taxes, Netherlands, Bitcoin Regulation
A comparison of an investment compounded over 40 years without the 36% unrealized gains tax and with the tax. Source: Investing Visuals

Crypto industry and tech executives in the United States voiced similar concerns about California’s proposed wealth tax on billionaires.

The proposal outlined a 5% tax on an individual’s net worth above the $1 billion threshold, igniting a torrent of backlash and tech entrepreneurs announcing that they were leaving the state of California.

Magazine: Best and worst countries for crypto taxes — plus crypto tax tips

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