China vs Singapore
Crypto regulation comparison
China
Singapore
China has imposed a comprehensive ban on cryptocurrency activities. In September 2021, the PBOC and ten other agencies jointly declared all cryptocurrency transactions illegal, and the State Council banned crypto mining. China is instead promoting the digital yuan (e-CNY) CBDC.
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
- All crypto transactions declared illegal by PBOC and 10 agencies in September 2021
- Crypto mining banned by the State Council in 2021 after a series of provincial crackdowns
- Financial institutions and payment companies prohibited from facilitating crypto services
- China actively developing and piloting the digital yuan (e-CNY) CBDC
- Despite the ban, some Chinese citizens reportedly access crypto via VPNs and OTC desks
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