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Hong Kong vs Singapore

Crypto regulation comparison

← Back to map | Hong Kong | Singapore
Hong Kong

Hong Kong

Singapore

Singapore

Legal
Legal

Hong Kong has positioned itself as a major crypto hub in Asia with a comprehensive licensing regime. The SFC implemented a mandatory licensing framework for virtual asset trading platforms (VATPs) effective June 2023. Hong Kong has no capital gains tax, making it attractive for crypto investors and businesses.

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 No tax
Tax Type Varies
Tax Rate 0%
Tax Rate 0%-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator SFC (Securities and Futures Commission), HKMA
Regulator MAS (Monetary Authority of Singapore)
Stablecoin Rules HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
Key Points
  • Mandatory VATP licensing regime under the AMLO effective June 1, 2023
  • No capital gains tax in Hong Kong; profits tax applies only to business profits
  • SFC approved spot Bitcoin and Ether ETFs for retail investors in April 2024
  • HKMA consulting on stablecoin issuer licensing under a dedicated bill
  • Hong Kong actively competes with Singapore as Asia's leading crypto hub
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
Sources