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Kyrgyzstan vs Singapore

Crypto regulation comparison

Kyrgyzstan

Kyrgyzstan

Singapore

Singapore

Legal
Legal

Kyrgyzstan adopted the Law on Virtual Assets in 2022 requiring licensing for exchanges, mining, and VASPs. Over 120 licensed VASPs operate. Crypto turnover exceeded traditional securities market in 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.

Tax Type Income
Tax Type Varies
Tax Rate 10%
Tax Rate 0%-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator State Financial Supervision Authority
Regulator MAS (Monetary Authority of Singapore)
Stablecoin Rules Regulated under Virtual Assets Law
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
Key Points
  • Law on Virtual Assets adopted in 2022 with licensing framework
  • Over 120 licensed VASPs active by late 2024
  • Three license types: trading operator, currency exchanger, mining operator
  • Crypto sector contributed 800M KGS in taxes in 2024
  • Virtual assets not recognized as legal tender but circulate under special regime
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