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Mauritius vs Singapore

Crypto regulation comparison

← Back to map | Mauritius | Singapore
Mauritius

Mauritius

Singapore

Singapore

Legal
Legal

Mauritius has developed a regulatory framework for virtual assets through the Financial Services Commission. The Virtual Asset and Initial Token Offering Services Act 2021 (VAITOS Act) provides licensing for VASPs. Mauritius positions itself as a fintech-friendly jurisdiction in Africa with a flat 15% income tax rate applicable to crypto income.

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%
Tax Rate 0%-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FSC (Financial Services Commission)
Regulator MAS (Monetary Authority of Singapore)
Stablecoin Rules Virtual assets regulated under FSC framework
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
Key Points
  • VAITOS Act 2021 provides comprehensive licensing for VASPs
  • FSC issues Class M (custodian), Class O (exchange), Class R (advisory) licenses
  • Flat 15% income tax rate applies to crypto income
  • No separate capital gains tax; gains may be treated as income
  • Mauritius is a member of FATF and complies with international AML standards
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
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