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Japan vs Singapore

Crypto regulation comparison

← Back to map | Japan | Singapore
Japan

Japan

Singapore

Singapore

Legal
Legal

Japan is one of the world's most comprehensively regulated crypto markets. The Payment Services Act and Financial Instruments and Exchange Act govern crypto exchanges and tokens. Japan classifies crypto as "crypto-assets" and taxes gains as miscellaneous income at rates up to 55%, though reforms to lower this rate are under active discussion.

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 Income
Tax Type Varies
Tax Rate 15-55%
Tax Rate 0%-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FSA (Financial Services Agency), JVCEA
Regulator MAS (Monetary Authority of Singapore)
Stablecoin Rules 2022 stablecoin law requires issuers to be licensed banks, trust companies, or fund transfer agents
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
Key Points
  • Crypto exchanges must register with the FSA under the Payment Services Act
  • Crypto gains taxed as miscellaneous income at up to 55% (national + local tax)
  • Japan's self-regulatory body JVCEA sets industry standards for exchanges
  • 2022 stablecoin legislation (revised Payment Services Act) regulates stablecoin issuance
  • Government considering tax reform to apply a flat 20% separate taxation on crypto gains
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