Georgia vs Singapore
Crypto regulation comparison
Georgia
Singapore
Georgia is one of the most crypto-friendly countries globally. There is no capital gains tax for individuals on cryptocurrency, and the country has a significant crypto mining industry due to low electricity costs. The National Bank has taken a cautious but permissive approach, issuing guidance rather than strict regulation.
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
- No capital gains tax on crypto for individuals
- Businesses dealing in crypto are taxed under standard corporate tax rules (15% CIT)
- Georgia is a major crypto mining hub due to cheap hydroelectric power
- NBG does not recognize crypto as legal tender but has not prohibited it
- The Free Industrial Zone offers additional tax advantages for crypto businesses
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