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Why the natural person comes first

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Founders tend to begin with the entity. They ask whether a Zug foundation or a Singapore company limited by guarantee is the better treasury vehicle, and only later notice that the answer depends on where they themselves will be tax resident when the tokens vest. That order of thinking is backwards. The entity can be moved, merged or liquidated. The founder's tax residence on the day a token becomes transferable, or on the day a vesting tranche is released, determines who taxes the gain and at what rate. That event cannot be undone once it has happened.

Four decisions therefore come in a fixed sequence. First, where will the founder and the founder's family live during the two to three years that surround the token event. Second, which entity holds the protocol treasury and which holds the operating business. Third, which licence or self-regulatory affiliation the operating business needs and where. Fourth, how the treasury is banked and converted. This chapter deals with the first decision. The later chapters assume it has been taken.

Two features of the two hubs make the comparison unusual. Switzerland taxes residents on worldwide income and wealth but exempts private capital gains. Some cantons also offer expenditure-based taxation to newcomers who do not work in Switzerland. Singapore taxes on a territorial basis, imposes no tax on capital gains, and exempts most foreign-sourced income of individuals, while taxing employment and trading income at progressive rates that top out at 24 per cent.1 A founder who understands these two systems can usually see within an hour which of them fits the shape of their expected income. The difficulty is in the detail: what counts as gainful activity, what counts as trading, and what the former home state does on the way out.

Notes

  1. Income Tax Act 1947 (2020 Rev. Ed.), s. 10(1), s. 13(7A) and Part B of the Second Schedule (resident rates from the year of assessment 2024). ↩

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.