- Bitcoin Treasuries
- Posts
- The Geographic Arbitrage Wars: How Tax Regimes Are Creating Bitcoin Proxy Empires
The Geographic Arbitrage Wars: How Tax Regimes Are Creating Bitcoin Proxy Empires
Bitcoin Balance Sheet #016
Bitcoin Treasuries
September 12, 2025
Hello and welcome to Bitcoin Balance Sheet, the new twice weekly email from Bitcoin Treasuries, where we track the latest in corporate Bitcoin buying.
Each Monday, you'll receive a quick blast on the top buyers over the last week. We'll follow that up every Friday with digest and analysis. Enjoy!
BTC in DC: Where Policy Meets Innovation
Want to meet the innovators, the regulators, the thinkers who are pushing Bitcoin forward?
Join us Sept 30 – Oct 1, 2025 at the Kennedy Center in Washington, D.C., for BTC in D.C. — where Bitcoin meets public policy.
Two days where you can learn from global experts, meet those shaping regulatory innovation, and connect to the people working at the intersection of Bitcoin, regulation, national security, and global economy.
Some of the key speakers include:
Senator Cynthia Lummis
Bitcoin author Parker Lewis
Blockstream CEO Adam Back
Strategy executive chairman Michael Saylor
The Bitcoin Bond Company’s Pierre Rochard
Secure your seat today, and help define what’s next for Bitcoin.
Bitcoin Treasuries subscribers receive 10% discount for the event, use code DOTNET and get your ticket, today.
The Geographic Bitcoin Proxy Wars
Across Asia, Europe, and Latin America, punitivie tax regimes are creating a new financial reality for investors: Bitcoin held by corporations in high-tax jurisdictions that is worth systematically more than sport price.
Because some countries acknowledge Bitcoin as legal tender, while others approach it as a commodity or an investment vehicle like equities, the Bitcoin market is fragmenting into tax-oriented fiefdoms, each with its own structural premium.
Japan created the ideal conditions for this arbitrage.
The country classifies crypto gains as "miscellaneous income," triggering progressive rates up to 55% with no loss offsets. Meanwhile, listed equities enjoy a flat 20% capital gains rate.
Consider the math: A Japanese investor who bought Bitcoin at $30,000 and sold at $130,000 would owe $55,000 in taxes on the $100,000 gain. If that same investor held Metaplanet shares instead, they would pay $20,000. That $35,000 difference on every $100,000 gain explains why investors are rationally accepting the premium pricing.
Japan's retail investment culture amplifies this effect. The country has one of the world's highest retail participation rates in financial markets, with Mrs. Watanabe — the archetypal Japanese retail investor — famous for sophisticated carry trades.
These investors understand leverage, premiums, and tax optimization. They're not overpaying for Metaplanet out of ignorance, but rather they're executing tax arbitrage.
Metaplanet has deployed over $2 billion to acquire 20,136 BTC at an average cost of around $102,000. The company’s ability to raise this capital — much of it through equity offerings at premium valuations — proves the model’s sustainability.
When shares trade at 1.4x to 2x mNAV, every billion raised at premium prices creates immediate value for existing shareholders. Moreover, the company's latest innovation — preferred stock pegged at 25% of Bitcoin NAV — ensures funding capacity even in severe downturns.
See the real-time Metaplanet premium: Live mNAV Chart
Korea is no stranger to premiums.
The "Kimchi Premium" — where Bitcoin trades 10-50% higher on Korean exchanges due to capital controls — has persisted for years. Now, with crypto taxation arriving in 2027, Korea is primed for its own Metaplanet moment.
One such firm already exists: Bitmax (ticker: 377030.KO), ranked #56 globally with 551.2 BTC, which quietly entered the Bitcoin treasury space in March 2025.
Trading at 1.76x mNAV with a market cap of 155 billion won ($112 million) against an enterprise value of just $140 million, Bitmax demonstrates that Korean markets are already pricing in future tax implications.
The timing is critical. Korea's crypto tax implementation, deferred multiple times, now targets 2027.
Bitmax is positioning ahead of the regulatory shift, accumulating Bitcoin while Korean investors can still trade crypto without triggering taxable events. When the 20% tax lands, Bitmax's first-mover advantage could translate into Metaplanet-style premiums.
Korea's retail trading culture makes this somewhat inevitable. Korean retail traders generate crypto volumes that regularly exceed the KOSPI's entire equity volume. Young Koreans coined "shibal biyong" (fuck-it expense) to describe YOLO trading mentality. When these traders face 20% tax rates in 2027, demand for tax-wrapped alternatives could explode.
The market structure also favors larger players entering soon. Samsung Securities manages 300 trillion won. KB Financial Group controls similar assets. Kakao's ecosystem reaches 50 million users. Any of these adding Bitcoin would dwarf Bitmax's holdings overnight.
But Bitmax provides a unique test model in that Korean investors are already paying 1.76x mNAV for tax-efficient Bitcoin exposure, even before the tax arrives.
Track Bitmax’s price vs. Bitcoin holdings before the 2027 tax shift: Korea Leaderboard
Europe has every ingredient for Bitcoin proxy arbitrage — except execution.
Yet the evidence is damning: Sequans Communications (#24, France) holds 3,205 BTC but trades at 0.38x mNAV. Capital B (#29, France) with 2,201 BTC trades at 1.37x mNAV. Bitcoin Group SE (#23, Germany) with 3,605 BTC trades at just 0.56x mNAV.
The disconnect is striking.
French companies should theoretically command premiums from domestic investors seeking to avoid 30% tax rates. German companies should attract French, Italian, and Spanish capital seeking tax efficiency.
Capital B shows early promise at 1.37x mNAV, suggesting French investors are beginning to recognize the tax wrapper value. But Sequans trading at a 62% discount to its Bitcoin holdings reveals the market hasn't connected the dots.
The opportunity remains massive. EU passporting allows free capital movement, creating a €15 trillion addressable market. The first European company to embrace the Metaplanet playbook — aggressively marketing itself as a tax wrapper rather than an operating company — will capture sustainable premiums.
Until then, Europe remains the most undervalued Bitcoin treasury market globally, with French and German companies trading below their Bitcoin holdings while Asian peers command 50-100% premiums.
Compare French and German treasuries trading below their Bitcoin holdings: Europe Leaderboard.
Latin America's Bitcoin proxy opportunity isn't about tax optimization — it's about solving access problems.
The continent already has its Bitcoin proxies.
MercadoLibre holds 570.4 BTC (#55 globally) and trades at an astounding 1,805x mNAV, but that's because its $119 billion market cap reflects its e-commerce dominance, not Bitcoin holdings. Brazil's Méliuz (604.7 BTC, #54 globally) trades at 1.39x mNAV, showing early premium emergence.
The opportunity isn't tax arbitrage — Brazil's 15-22.5% crypto taxes are reasonable, while Argentina recently eliminated certain crypto taxes.
Operational friction is the real problem in Latin America. Brazilian exchanges face banking restrictions, international platforms require complex compliance, and self-custody means navigating reporting nightmares.
Méliuz's 30 million users can now gain Bitcoin exposure through their cashback app. That convenience is worth the 39% premium.
MercadoLibre represents the bigger play, however. With 70 million users across Latin America already trusting it for payments and credit, adding meaningful Bitcoin allocation would transform it from e-commerce platform to regional financial infrastructure.
In markets where buying dollars requires black market dealings and inflation runs triple digits, legitimate Bitcoin exposure through a trusted app becomes invaluable.
The Latin American premium will be structural but different from Asia or Europe. Not tax arbitrage but infrastructure arbitrage. When Nubank (90 million users), Banco BTG Pactual, or other regional champions embrace Bitcoin treasuries at scale, they'll capture premiums reflecting the value of solving access, not optimizing taxes.
See which Latin American firms are emerging as Bitcoin proxies: LatAm Leaderboard.
Over To You: What Do You Track?
We want to make this the go-to resource for corporate Bitcoin strategy — and that means learning from our readers.
What metrics or dashboards do you rely on to track the space?
Which signals would you like us to explore in more depth?
What tools would you like to see us integrate?
You can help shape the direction of this newsletter in 10 seconds.
Just hit reply, we read everything.
For more information: