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The Swiss contrast

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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.

QuestionSingaporeSwitzerland
Individual, private capital gain on tokensNot taxedExempt (Art. 16 para. 3 DFTA)
Individual, professional traderTaxed as trade incomeTaxed as self-employment income, plus social security
Company, gain on tokens held as capitalNot taxedTaxed as profit
Company, gain on qualifying shareholdingNot taxed (capital)Participation relief
Foreign-sourced gains of group entitys. 10L if no substanceTaxed as profit in any event
Wealth taxNoneCantonal, on year-end value
Statutory safe harbour for investor statusNoneCircular 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.

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. 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 Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.