Where the hubs stand in 2026
Switzerland has, through the foundation and the association, the most developed practice in the world for giving protocols a legal home. Zug's supervisory and tax authorities have examined hundreds of protocol foundations and know what they are looking at. Singapore has, through the CLG, a workable but ill-fitting form and, since the DTSP regime, a regulatory environment in which a protocol wrapper that performs any service for the world is unwelcome. The combination most of the author's clients adopt in 2026 is a Swiss foundation or association for governance and treasury, a Singapore or other operating company for development and a careful separation between the two so that the Swiss entity never provides a service and the Singapore entity never holds the treasury. Part P, Chapter II and Chapter III set out the structuring in detail.
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.