Norway vs Singapore
Crypto regulation comparison
Norway
Singapore
Cryptocurrency is legal in Norway and regulated by Finanstilsynet. Norway taxes crypto capital gains at 22% and includes crypto holdings in the annual wealth tax calculation (net wealth above NOK 1.7M taxed at ~1.1%). VASPs must register with Finanstilsynet. Norway is an EEA member and aligning with MiCA through the EEA agreement.
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.
Key Points
- Crypto capital gains taxed at 22% flat rate
- Crypto included in wealth tax base (~1.1% on net wealth above threshold)
- VASPs must register with Finanstilsynet and comply with AML/CFT requirements
- Norway is a major crypto mining hub due to cheap hydroelectric power
- EEA member; MiCA implementation expected through EEA Agreement adaptation
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
- MAS - Guidelines on Licensing for DTSPs
- MAS - DPT Services Regulated in Singapore
- IRAS - Income Tax Treatment of Digital Tokens
- MAS - Strengthens Regulatory Measures for DPT
- MAS - Expands Scope of Regulated Payment Services
- MAS - Measures to Reduce Risks from Crypto Trading
- MAS - Regulatory Regime for Digital Token Service Providers