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Bhutan vs Singapore

Crypto regulation comparison

Bhutan

Bhutan

Singapore

Singapore

Legal
Legal

Bhutan has quietly become a significant Bitcoin miner through its government investment arm, Druk Holding & Investments, leveraging hydroelectric power. No tax on crypto.

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 No tax
Tax Type Varies
Tax Rate 0%
Tax Rate 0%-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator Royal Monetary Authority of Bhutan
Regulator MAS (Monetary Authority of Singapore)
Stablecoin Rules No specific stablecoin regulation
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
Key Points
  • Government entity Druk Holding & Investments mines Bitcoin
  • Hydroelectric power used for mining operations
  • No income or capital gains tax in Bhutan
  • Royal Monetary Authority provides oversight
  • One of the few countries with state-level crypto mining operations
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