Spain vs Singapore
Crypto regulation comparison
Spain
Singapore
Cryptocurrency is legal and increasingly regulated in Spain. Crypto capital gains are taxed at progressive savings tax rates (19-28%). Spain was an early mover in requiring crypto advertising to be pre-approved by the CNMV. Since 2024, Spanish taxpayers must report overseas crypto holdings via the Modelo 721 form. Banco de España registers VASPs for AML compliance. MiCA applies from December 2024.
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 at savings rates: 19% (first €6,000), 21%, 23%, 27%, 28% (above €300,000)
- Modelo 721: mandatory declaration of overseas crypto holdings exceeding €50,000 (from 2024)
- CNMV requires pre-approval of crypto advertising targeting Spanish residents
- Banco de España maintains VASP registry for AML compliance
- Spain has a large crypto-using population; significant expat and digital nomad community
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