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Germany vs Singapore

Crypto regulation comparison

Germany

Germany

Singapore

Singapore

Legal
Legal

Germany has one of the most well-defined crypto regulatory environments in Europe. BaFin has regulated crypto custody as a financial service since 2020. Notably, crypto held for over one year by individuals is completely tax-free, making Germany one of the most favorable jurisdictions for long-term holders.

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 Capital gains
Tax Type Varies
Tax Rate 0-45%
Tax Rate 0%-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht)
Regulator MAS (Monetary Authority of Singapore)
Stablecoin Rules Regulated under MiCA; BaFin already licensed crypto custody under existing German law since 2020
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
Key Points
  • Crypto held for more than 1 year is completely tax-free for individuals
  • Short-term gains (under 1 year) taxed as income at up to 45% plus solidarity surcharge
  • Annual exemption of €1,000 for short-term crypto gains (since 2024, previously €600)
  • BaFin licenses crypto custody businesses under the KWG (German Banking Act) since January 2020
  • MiCA framework applicable from December 2024, complementing existing German regulation
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