United Kingdom vs Singapore
Crypto regulation comparison
United Kingdom
Singapore
The UK has an evolving and increasingly comprehensive crypto regulatory framework. The FCA registers crypto firms for AML/CFT compliance and has imposed strict financial promotion rules requiring risk warnings and banning incentives. HMRC treats crypto as property subject to Capital Gains Tax (10% basic rate, 20% higher rate, with £3,000 annual exemption from 2024/25). The Financial Services and Markets Act 2023 brought crypto assets into the UK regulatory perimeter, and HM Treasury is developing rules for a full crypto regime including exchange licensing, stablecoin regulation, and a potential UK CBDC ('Britcoin').
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
- FCA AML registration required for all crypto firms operating in the UK
- Capital Gains Tax: 10% (basic rate) or 20% (higher rate); £3,000 annual exempt amount (2024/25)
- Financial promotions regime (2023): strict rules on crypto advertising, risk warnings mandatory
- Financial Services and Markets Act 2023 brings crypto into regulatory perimeter
- HM Treasury developing comprehensive crypto regulatory regime (exchange licensing, conduct rules)
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
- HMRC - Cryptoassets Manual
- FCA - Cryptoassets Information
- HMRC - Capital Gains Tax Rates
- HMRC - Cryptoassets Manual: Mining
- FCA - Regulation of Digital Assets Speech
- FCA - Cryptoasset Registration Application
- FCA - Regulating Cryptoasset Activities (DP25/1)
- FCA - Financial Promotion Rules for Cryptoassets (PS23/6)
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