Crypto company registration

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Lithuania

Estonia

Poland

Management board
Lithuania requires an experienced Director, but not a local one.
Estonia requires a local board member with good business reputation, education and experience.
No local board member requirement, however the BM must obtain a Polish taxpayer number and have at least 1 year experience in crypto industry or completed courses in this field.
AML officer
LT requires a experienced compliance person or 3rd party to provide for both KYC and transaction monitoring.

The AML officer must be a local resident.
Compliance officer must permanently work in Estonia and must prove impeccable business reputation. Compliance officer can hold the position only in 1 licensed company.
Poland does not require an AML officer. However, it is better to have one, for having your own compliance always in order.
Office
LT does not require a local physical office unless needed to acquire a VAT number. Headquarters can be located abroad.
The registered office of the company, the seat of the management board and the place of business must be in Estonia (foreign companies must be operating in Estonia through a branch which is registered in the commercial register and has its registered office and head office in Estonia).
In Poland virtual office is sufficient. No need for local physical office.
Criminal record requirement
Lithuania does not need a criminal record (unless the owners and directors are publicly listed with negative information), therefore, shareholders of the Lithuanian company are easy to sustain.
Estonia requires criminal records from all related persons and legal entities.
Poland requires criminal record certificate from all related persons and legal entities
Taxation
Lihtuania holds 3rd place in the OECD corporate taxation ranking (15% corporate tax, 15% withholding).
Estonia holds 1st place in the OECD corporate taxation ranking (0% corporate tax, 20% withholding).
Corporate income taxation is more complex in Poland and depend on the entity type, financial indicators, etc (up to 20%). The general withholding rate on interest and royalties paid to non-residents is 20%.
Capital requirement
Capital requirement in Lithuania is 125 000 EUR from 1st of November 2022 and must be paid in.
Capital requirement in Estonia is 100 000 EUR or 250 000 EUR depending on the activity and it must be paid in.
Minimum capital requirement is 5000 PLN, which equals to approx. 1100 EUR and must be paid in.
Employment costs
Lithuania’s employment is effectively up to 15% lower cost than in Estonia, considering the latest social tax contributions and average salary in the financial sector.
Estonia’s employment is effectively up to 15% higher cost than Lithuania, considering the latest social tax contributions and average salary in the financial sector.
There is no requirement to hire Polish employees. Polish employment is cheaper than in Lithuania and Estonia, considering the latest social tax contributions and average salary in the financial sector
Accounting costs
Accounting costs are dependent on company transactions, nevertheless, accountant gross salary in Lithuania is 1570 EUR according to salary explorer.
Accounting costs are dependent on company transactions, nevertheless, accountant gross salary in Estonia is 1870 EUR according to salary explorer.
Accounting costs: from 200 EUR net + VAT 23% monthly, however the final monthly payment depends on number of documents and positions on bank extract.
Estimated setup fees and monthly maintenance costs
Starting from 7 500 EUR + share capital (new entity registration and crypto license application).

Monthly costs up to 2000 EUR (accounting, virtual office, etc.).
Estimated 50 000 EUR for the setup + share capital (new entity registration and crypto license application).

Monthly costs start from 10 000 EUR (office rent, average salary costs (incl. taxes), accounting).
Starting from 10 000 EUR + share capital (new entity registration and crypto license application).

Monthly costs up to 1000 EUR (accounting, virtual office, etc.)
State fee
Lithuanian state fee is approx. EUR 230 and up to 4 weeks of timing to consider the license application.
Estonian crypto exchange state fee is EUR 10 000 and up to 12 weeks to consider the license application.
State fee is approx. 140 EUR in Poland and 2-4 weeks to consider the license application.
License issuer
Lithuanian license is issued by the Registry and legislated by the Bank of Lithuania (also forms to this authorization are addressed to the Bank of Lithuania) and its division Financial Crime Investigation Services (FCIS).
Estonia has a separate Financial Intelligence Unit for crypto licensing.
Licenses are issued and registered by Polish Chamber of Tax Administration in Katowice.
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