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Where the hubs stand in 2026

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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.

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.