Hong Kong and Singapore compared

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The following table sets the two Asian hubs side by side as at 30 June 2026, with Switzerland in a third column where the comparison helps.

Question	Hong Kong	Singapore	Switzerland
Regulator	SFC (platforms, intermediaries, funds); HKMA (banks, stablecoins)	MAS (integrated)	FINMA; SROs; SNB
Exchange licence	AMLO Part 5B VATP licence plus SFO Types 1 and 7 for security tokens	PSA DPT licence (SPI/MPI); RMO for securities	SRO; fintech/bank licence if deposits; DLT trading facility for securities
Retail access	Permitted on licensed platforms; large-cap tokens only; knowledge test	Permitted with restrictions on incentives, credit, staking, marketing	No retail-specific rules
Custody	Associated entity on trust; 98 % cold; compensation arrangement	Statutory trust; majority cold; daily reconciliation	Art. 242a DEBA segregation
Stablecoins	Stablecoins Ordinance in force 1 August 2025; HKMA licence; HK$ 25 million capital	SCS framework (2023); legislation pending	Deposit or CISA characterisation; FINMA Guidance 06/2024
Staking for retail	Permitted via licensed VATPs since April 2025	Barred	Unregulated (deposit question for custodial staking)
Spot crypto ETFs	Authorised since April 2024	Not authorised for retail	ETPs on SIX since 2018
Offshore-serving businesses	Not captured unless marketing to Hong Kong	Captured by FSMA Part 9 since 30 June 2025	Captured if operated from Switzerland
Capital gains tax	None	None	None for private individuals; wealth tax applies
Profits/corporate tax	16.5 %	17 %	Approx. 12 % (Zug) to 20 % (Zürich)
GST/VAT on token trades	No GST	GST-exempt	VAT-exempt
Property characterisation	Re Gatecoin (2023)	ByBit (2023)	Factual power of disposal; ledger-based securities
Mainland China access	Gateway; e-CNY and mBridge; Stock Connect model	None specific	None

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

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Setting up or expanding in Singapore?

SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. As a Singapore law practice, KGP Legal LLC is authorised under the Legal Profession Act 1966 to advise on Singapore law and to represent clients before the Singapore courts; foreign law practices with an office in Singapore are, as a rule, not permitted to do either. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.