The Swiss contrast
Switzerland exempts private capital gains for individuals (Art. 16 para. 3 DFTA) and taxes capital gains of companies as ordinary profit, subject to the participation relief for qualifying shareholdings. Singapore does the reverse in one respect: it exempts capital gains for companies as well as for individuals, provided they are capital, and has no participation relief because it needs none. A Swiss AG that sells tokens held as treasury investments pays profit tax on the gain. A Singapore Pte Ltd that sells tokens held as capital pays nothing. For a corporate treasury the Singapore position is more favourable, with section 10L as the only statutory qualification and the badges of trade as the only practical one.
| Question | Singapore | Switzerland |
|---|---|---|
| Individual, private capital gain on tokens | Not taxed | Exempt (Art. 16 para. 3 DFTA) |
| Individual, professional trader | Taxed as trade income | Taxed as self-employment income, plus social security |
| Company, gain on tokens held as capital | Not taxed | Taxed as profit |
| Company, gain on qualifying shareholding | Not taxed (capital) | Participation relief |
| Foreign-sourced gains of group entity | s. 10L if no substance | Taxed as profit in any event |
| Wealth tax | None | Cantonal, on year-end value |
| Statutory safe harbour for investor status | None | Circular 36 criteria |
The comparison explains why many protocol treasuries sit in Singapore companies while the foundation that controls them sits in Zug. Part P, Chapter IV describes the pattern and its weaknesses, among them the FSIE headline-rate problem, the substance cost and the growing reach of section 10L.
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.