Bulgaria vs Singapore
Crypto regulation comparison
Bulgaria
Singapore
Cryptocurrency is legal in Bulgaria and subject to a flat 10% tax on capital gains, one of the lowest in the EU. Bulgaria adopted the EU's MiCA framework and requires crypto service providers to register. The country has a notable history with crypto due to a large government Bitcoin seizure in 2017.
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
- Flat 10% personal income tax rate applies to crypto capital gains
- VASPs must register with the NRA for AML compliance
- MiCA framework applicable from December 2024
- Bulgaria reportedly seized approximately 200,000 BTC in a 2017 crime bust (status debated)
- No specific crypto legislation beyond EU directives and general tax law
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