Singapore vs Thailand
Crypto regulation comparison
Singapore
Thailand
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.
Thailand has a comprehensive crypto regulatory framework under the Digital Asset Business Emergency Decree (2018). The SEC Thailand licenses digital asset exchanges, brokers, and dealers. Crypto gains are taxed at 15% withholding tax, though the government exempted VAT on crypto trading on authorized exchanges from 2022. Thailand has a well-developed exchange ecosystem with Bitkub as the dominant platform.
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
- Digital Asset Business Emergency Decree B.E. 2561 (2018) provides comprehensive regulation
- SEC Thailand licenses exchanges, brokers, dealers, and fund managers for digital assets
- 15% withholding tax on crypto gains; VAT exempted on authorized exchange trades since 2022
- BOT restricts crypto for payments but allows it as an investment asset
- Bitkub is the dominant exchange (~90% market share domestically)
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