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The Two Hubs: Why Switzerland and Singapore

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Two small countries, one at the centre of Europe and one at the tip of the Malay peninsula, have become the places where serious digital-asset businesses choose to live. Neither has the market depth of New York, the regulatory mass of the European Union or the capital of the Gulf. Both have something that the larger jurisdictions struggle to offer: a legal order that was ready for the asset class early, a regulator that talks to applicants, a tax system that rewards patient holding, and courts that have already decided what a token is. This book is about how those two orders work, where they resemble each other, where they diverge, and how a founder, an investor, a trustee or a fellow adviser can use both without falling between them.

The book is written from practice. For more than twenty years I have advised clients who move between legal systems, first from Singapore and Hong Kong, later from Düsseldorf, Frankfurt and Zürich, most recently from Zug. Digital assets entered that practice around 2016, when the first Zug foundations asked whether a token sale was a securities offering and the first Singapore funds asked whether a Bitcoin position was a "designated investment". The questions have become more sophisticated since then, although the underlying problem has stayed the same. A client has a business or a fortune built on a technology that ignores borders, yet must still choose a jurisdiction for the company, the licence, the custody, the tax residence and the court.

Part A sets the stage. It explains who the reader is and which decisions the book supports. It then describes the two hubs in enough detail that the later parts can be read in either order, introduces the comparative method that runs through the book and tells the regulatory history of both places from 2013 to mid-2026. Readers who already know one of the two systems can skip the corresponding chapter. Readers who know both may still find the comparative method in Chapter V useful, because it fixes the vocabulary used in Parts O, P and Q.

Everything in this book states the law as it stood on 30 June 2026. Citations to primary sources appear in footnotes.

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. 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.