How Jurisdiction Shapes Capital Strategy

Introduction: Why Jurisdiction Matters for Bitcoin Treasury Companies

We’re watching the rise of a new asset class: Bitcoin-native equities. These are public companies that don’t just hold Bitcoin—they structure their entire balance sheet around it. The capital design is as important as the BTC on the books.

As Bitcoin adoption accelerates across global capital markets, a new breed of companies has emerged: Bitcoin treasury companies. These are businesses—like Strategy (formerly MicroStrategy), Metaplanet, and The Blockchain Group—that actively acquire Bitcoin as a strategic reserve asset and engineer capital structures to maximize Bitcoin per share.

But not all jurisdictions are equal. Local laws, capital markets, and tax regimes shape the tools available to these companies. This article compares key jurisdictions—Japan, France, Sweden, the UK, the U.S., Canada, and Brazil—highlighting how different environments enable (or limit) their ability to raise, structure, and grow capital through Bitcoin. This goes beyond tax arbitrage—it’s about understanding structural edge.

If you’re leading treasury, finance, or strategic planning at a public company, this piece will help you understand what’s working, where, and why.

Let’s explore how each jurisdiction shapes the Bitcoin treasury toolkit—starting with the companies building in them.

🇯🇵 Japan: Ultra-Low Rates, NISA-Driven Retail, and Debt-Led BTC Expansion

Metaplanet has become Japan’s flagship Bitcoin treasury company—and was the top-performing public company globally in 2024, out of more than 55,000 tracked. It transitioned from a struggling hotel operator into a financial vehicle for long-term Bitcoin accumulation, leveraging Japan’s ultra-low interest rates and tax-free investment accounts to issue 0% coupon debt (redeemable at a premium) and attract retail inflows. With no domestic Bitcoin ETF, Metaplanet has become the retail proxy of choice.

Company: Metaplanet (TSE: 3350)
Key Tools: 0% interest debt (redeemable at premium), equity placements, retail demand via NISA accounts

• Capital Stack in Use: Metaplanet raised capital through both equity and debt. Most notable: a zero-coupon ¥2B bond redeemable at a 3% premium, and multiple strategic placements at premiums to market.
• Market Advantage: Japan’s ultra-low interest rates make debt cheap. The lack of a domestic spot BTC ETF funnels retail into equities.
• Retail Wrapper Impact: Metaplanet shares are NISA-eligible, meaning retail investors pay 0% tax on gains/dividends.
• Result: Metaplanet became Japan’s #1 NISA stock at SBI. Leverage + tax-advantaged retail demand created strong secondary market tailwinds.

🇫🇷 France: PEA Wrapper Unlocks Long-Term Capital; Controlled Float and ATMs

The Blockchain Group (ALTBG) reintroduced itself as Europe’s first Bitcoin treasury company in late 2024. It strategically positioned its shares to qualify for France’s PEA-PME wrapper, which offers tax-free gains after five years. ALTBG met the requirements for PEA-PME eligibility through its size, listing status, and ownership structure, and has actively promoted this advantage to long-term French investors. By maintaining a tight float and working with TOBAM on a large ATM program, ALTBG has created a long-term shareholder base with low churn and scalable capital access.

Company: The Blockchain Group (Euronext Growth: ALTBG)
Key Tools: PEA eligibility, low-float equity, at-the-market (ATM) program

• Capital Stack in Use: ALTBG completed premium-priced equity placements and launched a €300M ATM with TOBAM. Only ~€14M has been drawn to date.
• Bitcoin Holdings: As of June 2025, ALTBG holds 1,653 BTC at an average purchase price of ~$36,300.
• Market Advantage: Shares are PEA-PME eligible, enabling 0% capital gains tax after 5 years. This attracts long-term holders.
• Retail & Institutional Access: PEA structures are widely used by French investors. The company also partnered with asset managers (e.g. TOBAM) to structure placements.
• Result: Tight float + long-term tax shield = strong upward pressure and investor loyalty. ATM gives flexible capital intake at scale.

🇸🇪 Sweden: ISK Tax Efficiency, Convertible Bond Financing, Early-Stage Exposure

H100 Group is positioning itself as Sweden’s first Bitcoin-native public company—reengineering its capital stack to prioritize long-term Bitcoin accumulation. Since announcing its Bitcoin treasury strategy in mid-2025, H100 has secured over SEK 265 million in committed financing across multiple tranches of convertible loans, including a SEK 150 million facility from Adam Back and further tranches from Eagles Rising AB. The company is also working with STOKR to explore a tokenized convertible bond, signaling intent to merge traditional capital markets with the global Bitcoin ecosystem. For Swedish investors, H100’s shares offer a rare structural advantage: they’re eligible for ISK accounts, which impose a flat yield tax (~0.89%) on portfolio value—unlike direct crypto, which is taxed separately and cannot be held in tax wrappers. This makes H100 equity a uniquely tax-efficient proxy for long-term BTC exposure in Sweden.

Company: H100 Group (NGM: H100)

• Capital Stack in Use: Raised over SEK 265 million via a multi-tranche convertible loan framework backed by investors including Adam Back and Eagles Rising AB. Partnered with STOKR to explore tokenized bond issuance.
• Retail Structure: Shares are ISK-compatible, allowing Swedish investors to hold H100 stock in accounts taxed at a low flat annual rate (~0.89%) on total portfolio value.
• Regulatory Advantage: Crypto is barred from ISK accounts—but Bitcoin-aligned equities are permitted, making H100 a rare BTC exposure vehicle within Sweden’s tax shelters.
• Result: H100 has laid the financial foundation for long-term Bitcoin accumulation while pioneering compliant capital innovation in the Nordic region.

🇬🇧 United Kingdom: ISA Access Drives Demand; Equity-Led Growth via Aquis

The Smarter Web Company emerged in 2025 as the UK’s first true Bitcoin treasury company—and quickly became one of the most explosive public listings in British market history. Originally a web services firm, it repositioned around a Bitcoin-forward balance sheet and tapped into the ISA/SIPP-eligible equity market to raise capital tax-efficiently from retail investors. While crypto is barred from UK tax wrappers, SWC shares are eligible—offering 0% capital gains and dividend tax. The company used a mix of institutional bookbuilds, WRAP offers, and shareholder allocation rounds to accelerate its Bitcoin accumulation. By mid-year, it had surpassed £1B in market cap and briefly became the most successful IPO in UK financial history by post-IPO share performance.

Company: The Smarter Web Company (AQUIS: SWC)
Key Tools: ISA/SIPP eligibility, accelerated book builds, WRAP retail offers

• Capital Stack in Use: Raised capital through institutional bookbuilds, WRAP retail offers, and strategic shareholder allocation rounds—with strong investor participation.
• Retail Tax Advantage: Shares are ISA/SIPP eligible, enabling 0% tax on capital gains and dividends—unlike direct crypto, which is excluded.
• Market Context: In the absence of Bitcoin ETF access, SWC became a preferred tax-free BTC proxy for UK retail investors.
• Result: Shares surged over 10,000% from IPO before stabilizing. SWC became the top-performing ISA stock in its class, demonstrating the power of wrapper-eligible BTC equity.

🇺🇸 United States: Debt Innovation, Preferred Equity, and Global Liquidity Access

The United States remains the center of global capital markets—and Strategy (formerly MicroStrategy) has used every tool in the U.S. playbook to build the world’s largest corporate Bitcoin treasury. Through flexible securities law, deep liquidity, and access to both institutional and retail investors, Strategy has financed the purchase of 592,000+ BTC as of June 2025. But its real innovation lies in how it finances that accumulation—through a dynamic capital stack built specifically for Bitcoin exposure.

Company: Strategy (NASDAQ: MSTR)
Key Tools: Convertible notes, secured bonds, ATM equity, preferred equity ($STRF, $STRK, $STRD)

• Capital Stack in Use: Strategy pioneered the 0% coupon convertible, issued secured bonds, executed ATM equity offerings, and in 2025 raised $1B through STRD, a Bitcoin-linked preferred stock. Its capital stack comprises:
  • Convertible Notes: Senior debt with optional upside; raised billions early on at low rates
  • $STRF (Strife): Non-convertible preferred with 10% dividend; fixed-income appeal
  • $STRK (Strike): Convertible preferred with 8% yield + upside; hybrid structure
  • $STRD (Stride): Junior preferred with high-yield and risk; supports senior tranches
  • Common Equity ($MSTR): Bitcoin beta; volatile, long-only upside
• Fixed Income Penetration: The STR-series offerings represent Strategy’s push into the $135–150 trillion global fixed income market, creating structured Bitcoin exposure for institutions unable to buy BTC directly.
• Investor Access: MSTR and its STR-pref equities are widely held in IRAs, 401(k)s, and institutional vehicles. While there’s no Bitcoin ETF in the U.S., Strategy has become a functional proxy.
• Result: Strategy remains the global benchmark for Bitcoin treasury operations—combining capital efficiency, narrative control, and financial product innovation across debt and equity markets.

🇨🇦 Canada: Bitcoin ETFs in TFSA, Venture Listings, and Bitcoin-Native Businesses

LQWD Technologies has positioned itself as Canada’s only Lightning-native Bitcoin treasury company—actively deploying BTC to grow global Lightning liquidity while preserving long-term upside. In a market already accustomed to spot Bitcoin ETFs and crypto-native public companies, LQWD benefits from strong regulatory optics and capital access. Canadian investors can hold LQWD shares inside TFSA accounts, allowing for tax-free capital growth. The company has raised capital through TSXV placements and structured follow-on raises post-IPO to expand its BTC reserves and Lightning infrastructure.

Company: LQWD Technologies (TSXV: LQWD)
Key Tools: TSXV listings, Lightning Network deployment, TFSA/RRSP eligible equity

• Capital Stack in Use: Raised capital through TSXV venture placements and follow-on raises post-IPO to expand BTC operations.
• Market Context: Operates BTC as working capital—fueling Lightning Network liquidity rather than passive storage.
• Investor Access: Shares are TFSA/RRSP eligible, allowing tax-free growth for Canadian retail holders.
• Result: LQWD combines Bitcoin infrastructure operations with BTC treasury growth, offering hybrid exposure for investors in Canada’s tax-sheltered ecosystem.

🇧🇷 Brazil: High-Yield Environment, Bitcoin as Hard Money Hedge

Méliuz pivoted from cashback fintech to Bitcoin treasury leader in 2025, raising $32.4 million in an oversubscribed follow‑on share offering and immediately deploying the proceeds to buy 275.43 BTC. That lifted its treasury to 595.67 BTC—the largest corporate Bitcoin holding in Latin America and 36th worldwide. With inflation above 7% and elevated interest rates, Bitcoin offers a clear appeal as a hard-money hedge for Brazilian investors.

While Brazil still lacks crypto-aligned tax wrappers or a spot ETF, Méliuz’s listing structure positions it well for equity-based retail access. The company retains strategic flexibility to explore future capital tools as regulation matures.

As a contrast: MercadoLibre also holds Bitcoin on its balance sheet, but as a reserve—not a treasury strategy. Méliuz, by comparison, is building a capital model around Bitcoin accumulation.

Company: Méliuz (BVMF: CASH3)
Key Tools: Follow‑on equity raise, direct BTC purchases, long-term capital flexibility

• Capital Stack in Use: Raised $32.4 million via follow‑on (June 2025) at a 5% discount to market; used proceeds to acquire 275.43 BTC at an average of $103,864/BTC. Total treasury now 595.67 BTC at avg cost $102,703/BTC.
• Macro Context: High inflation and unstable currency conditions make Bitcoin attractive to both retail and institutional allocators.
• Investor Access: No tax wrappers or ETF, but equity can be held directly by retail and institutional investors; additional tools like tokenized bonds or dual listings may follow.
• Result: Share price +110 % since BTC pivot; Méliuz became the largest listed Bitcoin holder in LatAm, with growing visibility and structural upside.

Conclusion: Jurisdiction Is a Strategic Variable—Not a Constraint

The rise of Bitcoin treasury companies has exposed a crucial truth: jurisdiction shapes outcome. Not just in terms of tax—but in capital access, product design, investor base composition, and narrative momentum.

Companies like Metaplanet, ALTBG, and Strategy aren’t merely executing Bitcoin accumulation—they’re engineering it through local advantage.

Some environments favor retail wrappers. Others offer institutional depth. And the rare few, like Japan or the U.S., provide both scale and structural innovation. What matters is understanding the full toolkit available—and how Bitcoin-native capital structures can be matched to jurisdictional edge.

For CFOs, strategy officers, and capital market leads, the key questions now are:

• What tools does your market allow—and which are being underutilized?
• Can wrapper eligibility or debt instruments create asymmetric BTC inflows?
• Are you structured for capital velocity—or constrained by legacy architecture?

Bitcoin is the constant. Jurisdiction is the variable.
The next corporate advantage won’t come from software margins—it will come from balance sheet design.

Disclaimer: This content was written on behalf of Bitcoin For Corporations. This article is intended solely for informational purposes and should not be interpreted as an invitation or solicitation to acquire, purchase, or subscribe for securities.