1. Goods or Assets:
In some countries, cryptocurrencies are considered movable goods or assets and taxed accordingly (e.g., the USA).

2. Electronic Money:
For cryptocurrencies to be recognized as "electronic money," they typically need to be tied to a central authority. However, decentralized cryptocurrencies like Bitcoin do not meet this definition.

3. Securities:
Some crypto assets, especially those offered through token sales (ICO/ITO), are considered securities and are subject to capital market regulations.

4. Equivalent Payment Instrument:
In some countries, cryptocurrencies are accepted as a limited payment method. However, this approach has not found a broad legal foundation.

5. Unregulated or Banned Assets:
In some countries, cryptocurrencies are either completely banned or considered unregulated (e.g., China).

Legal Status of Cryptocurrencies in Turkey

1. Definition and Legal Framework:
The Regulation on the Non-Use of Crypto Assets in Payments dated April 16, 2021, prohibits the use of crypto assets as a payment instrument.
Crypto assets are not recognized as electronic money or a legal payment method.

2. Capital Markets and Taxation:
The Capital Markets Board (SPK) has not issued specific regulations on whether crypto assets can be considered securities. However, processes similar to ICOs require SPK's approval and regulation.
There is no clear legislation on the taxation of crypto income. However, profits may be subject to income tax or corporate tax.

3. Crypto Exchange Regulations:
Crypto exchanges are required to register with MASAK and report suspicious transactions.
MASAK actively uses inspection and penalty mechanisms for exchanges.

4. Legal Issues:
There are legal gaps regarding the assessment of crypto assets in inheritance, enforcement, and bankruptcy law.

Different Approaches Worldwide

1. Permissive and Supportive Countries
USA:
Cryptocurrencies like Bitcoin and Ethereum are recognized as "property."
The SEC (Securities and Exchange Commission) classifies certain tokens as securities.
Taxation is applied through capital gains tax.

European Union:
Crypto assets are beginning to be regulated under the EU's MiCA (Markets in Crypto-Assets) regulation.
Member states can implement their internal regulations, but a common framework is being established across the EU.

El Salvador:
Bitcoin was recognized as legal tender in 2021.

2. Restrictive or Prohibitive Countries
China:
Cryptocurrency mining and trading are banned.
Instead, the central bank's digital currency (CBDC), the Digital Yuan, has been developed.

India:
The government is exploring ways to either regulate or ban crypto assets. Currently, high taxes are imposed on crypto income.

3. Countries Supporting Cryptocurrencies with Central Bank Digital Currencies
Sweden: The e-Krona project has initiated studies on digital currency.
Nigeria: A central bank digital currency called e-Naira has been developed.

Conclusion

The legal status of cryptocurrencies is challenging to define due to the nature of the technology. Global approaches generally revolve around three main axes:

1. Establishing a legal framework (EU, USA),

2. Imposing partial bans (China, India),

3. Fully integrating cryptocurrencies (El Salvador).

Turkey is in the process of developing its regulations and may establish a more comprehensive framework influenced by international examples.