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Luxembourg vs Singapore

Crypto regulation comparison

Luxembourg

Luxembourg

Singapore

Singapore

Legal
Legal

Luxembourg is a major European hub for crypto and blockchain financial services. The CSSF regulates VASPs and crypto-related investment funds. Crypto held for more than 6 months is generally exempt from capital gains tax for individuals, making it attractive for long-term holders. Luxembourg hosts several prominent crypto exchanges and fund administrators.

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 Capital gains
Tax Type Varies
Tax Rate 0-42%
Tax Rate 0%-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator CSSF (Commission de Surveillance du Secteur Financier)
Regulator MAS (Monetary Authority of Singapore)
Stablecoin Rules Regulated under EU MiCA framework; Luxembourg hosts major stablecoin issuers
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
Key Points
  • CSSF oversees VASPs under the Luxembourg AML/CFT framework
  • Individuals holding crypto for 6+ months are generally exempt from capital gains tax
  • Short-term gains taxed at progressive income tax rates up to 42%
  • Major hub for crypto investment funds and blockchain companies
  • MiCA framework fully applicable from December 2024
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