United Arab Emirates vs Singapore
Crypto regulation comparison
United Arab Emirates
Singapore
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.
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
Sources
Sources
- MAS - Guidelines on Licensing for DTSPs
- MAS - DPT Services Regulated in Singapore
- IRAS - Income Tax Treatment of Digital Tokens
- MAS - Strengthens Regulatory Measures for DPT
- MAS - Expands Scope of Regulated Payment Services
- MAS - Measures to Reduce Risks from Crypto Trading
- MAS - Regulatory Regime for Digital Token Service Providers