Denmark vs Singapore
Crypto regulation comparison
Denmark
Singapore
Cryptocurrency is legal in Denmark and regulated under EU frameworks including MiCA. Denmark has notably high tax rates on crypto gains, treated as personal income and taxed at rates up to 52%. The Danish Tax Council confirmed in 2018 that gains and losses on Bitcoin are taxable.
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
- Crypto gains taxed as personal income at 37-52% (among the highest in the world)
- Losses on crypto can be deducted against gains
- Finanstilsynet supervises crypto businesses under the Danish AML Act
- Denmark does not have its own crypto-specific legislation beyond EU frameworks
- Skattestyrelsen (tax authority) actively monitors crypto transactions and issues guidance
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
- 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