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United Arab Emirates vs Singapore

Crypto regulation comparison

United Arab Emirates

United Arab Emirates

Singapore

Singapore

Legal
Legal

The UAE has become a global crypto hub with multiple regulatory frameworks. Dubai's VARA (Virtual Assets Regulatory Authority), established in 2022, is the world's first dedicated crypto regulator and licenses exchanges, brokers, and other VASPs. Abu Dhabi's ADGM regulates crypto through the FSRA. The federal SCA also oversees crypto at the national level. The UAE has no personal income or capital gains tax. Major global exchanges (Binance, Bybit, OKX, Crypto.com) have obtained UAE licenses.

Singapore is a leading global crypto hub with a comprehensive regulatory framework under the Payment Services Act (PSA) 2019, amended in 2022. MAS licenses Digital Payment Token (DPT) service providers for AML/KYC compliance and consumer protection. Singapore has no capital gains tax, making it attractive for crypto businesses and investors. However, MAS has progressively tightened retail investor protections, restricting crypto advertising and requiring risk warnings. Short term trading gains is considered income and taxed as such.

Tax Type None
Tax Type Varies
Tax Rate 0%
Tax Rate 0%-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator VARA (Dubai), ADGM/FSRA (Abu Dhabi), SCA (Federal), CBUAE
Regulator MAS (Monetary Authority of Singapore)
Stablecoin Rules VARA regulates stablecoins in Dubai; ADGM has separate framework
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
Key Points
  • VARA (Dubai) — world's first standalone virtual asset regulator; comprehensive licensing framework
  • ADGM/FSRA (Abu Dhabi) — separate regulatory framework for digital assets in the financial free zone
  • No personal income tax or capital gains tax in the UAE
  • 9% corporate tax (from 2023) may apply to crypto businesses but not individual investors
  • Major exchanges licensed: Binance, Bybit, OKX, Crypto.com, BitOasis
Key Points
  • Payment Services Act (PSA) 2019 provides licensing for Digital Payment Token (DPT) services
  • MAS issues Major Payment Institution (MPI) and Standard Payment Institution (SPI) licenses for crypto
  • No capital gains tax on crypto for individuals; trading profits may be taxed if deemed business income
  • MAS introduced stablecoin regulatory framework in August 2023 for SG$-pegged stablecoins
  • Strict retail investor protection: crypto advertising restricted, no incentives for trading