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Singapore vs El Salvador

Crypto regulation comparison

← Back to map | Singapore | El Salvador
Singapore

Singapore

El Salvador

El Salvador

Legal
Legal

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.

El Salvador made history in September 2021 by becoming the first country to adopt Bitcoin as legal tender through the Bitcoin Law. However, under a January 2025 IMF agreement (Decreto 199), El Salvador amended the law to make Bitcoin acceptance by businesses voluntary rather than mandatory, and repealed several articles. There is no capital gains tax on Bitcoin. The CNAD regulates digital assets.

Tax Type Varies
Tax Type No tax
Tax Rate 0%-24%
Tax Rate 0%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator MAS (Monetary Authority of Singapore)
Regulator BCR (Banco Central de Reserva), CNAD (Comisión Nacional de Activos Digitales)
Stablecoin Rules MAS-regulated stablecoin framework (2023); SG-dollar stablecoins must meet reserve and disclosure requirements
Stablecoin Rules USD is the primary currency; Bitcoin-specific legislation in place
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
Key Points
  • First country to adopt Bitcoin as legal tender in September 2021 via the Bitcoin Law
  • Government developed the Chivo wallet for citizens, offering $30 USD in BTC incentive
  • January 2025 Decreto 199 made merchant Bitcoin acceptance voluntary (IMF condition)
  • No capital gains tax on Bitcoin transactions for individuals
  • Government has been accumulating Bitcoin reserves and launched Bitcoin-backed bonds
Sources
Sources