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China vs Singapore

Crypto regulation comparison

China

China

Singapore

Singapore

Banned
Legal

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.

Tax Type Unclear
Tax Type Varies
Tax Rate N/A
Tax Rate 0%-24%
Exchanges No No
Exchanges Yes Yes
Mining No No
Mining Yes Yes
Regulator PBOC (People's Bank of China), CBIRC, CSRC
Regulator MAS (Monetary Authority of Singapore)
Stablecoin Rules Not applicable; all crypto activities are banned
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
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