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Netherlands vs Singapore

Crypto regulation comparison

Netherlands

Netherlands

Singapore

Singapore

Legal
Legal

The Netherlands has one of Europe's strictest crypto regulatory regimes. DNB has overseen VASP registration since 2020 under the Dutch AML/CFT Act (Wwft), and many applications have been rejected. The Netherlands does not tax realized capital gains directly; instead, crypto holdings are taxed under the Box 3 wealth tax based on a deemed return on net assets. The AFM oversees market conduct. MiCA is now the governing framework.

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 Wealth
Tax Type Varies
Tax Rate ~1.2-1.6% (deemed return)
Tax Rate 0%-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator DNB (De Nederlandsche Bank), AFM (Autoriteit Financiële Markten)
Regulator MAS (Monetary Authority of Singapore)
Stablecoin Rules Regulated under EU MiCA framework; DNB oversight
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
Key Points
  • DNB requires VASP registration under the Wwft (AML Act); rigorous approval process
  • Only a limited number of VASPs have obtained DNB registration (many rejected or withdrawn)
  • Crypto taxed under Box 3 wealth tax: deemed return on net assets taxed at ~31-36% (effective ~1.2-1.6%)
  • AFM regulates crypto advertising and market conduct; banned crypto ads targeting retail in 2022
  • MiCA framework applicable from December 2024, transitioning from national DNB 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