COMPARATIVE ANALYSIS OF THE LEGAL REGIMES OF DIGITAL ASSETS

Digital assets such as cryptocurrencies and tokens are becoming an important part of the global economy, due to their growing popularity among investors, businesses and even states. However, the legal status of these assets varies from country to country depending on the economic situation, the level of digitalization and the specifics of legislation. A comparative analysis of the legal regimes of digital assets in Kyrgyzstan, Russia, the European Union, the USA, China, and Japan is carried out. The features of regulation of cryptocurrencies and other digital assets in these countries are considered, with an emphasis on their legal status, taxation and legislative initiatives. The purpose of the study is to identify similarities and differences in approaches to the legal regulation of digital assets, as well as to assess the legal risks and prospects for participants in this market, especially for the Kyrgyz Republic. It is noted that the legislator of the Kyrgyz Republic should take into account the experience of advanced countries in the legal regulation of digital assets and, when creating norms, focus on the best international practices, ensuring transparency, user protection and support for technological innovations.