新加坡（五）：税务与激励——Alexander Ressos博士著作《新加坡与瑞士数字资产法》（Digital Assets Law in Singapore and Switzerland）的一部分。
新加坡（五）：税务与激励：Alexander Ressos博士著作《新加坡与瑞士数字资产法》（Digital Assets Law in Singapore and Switzerland）的一部分。
本部分属于Alexander Ressos博士的著作新加坡与瑞士数字资产法，全书在本站逐节完整发布。
新加坡V：税收与激励措施
Tax is the reason many clients first look at Singapore and the reason some of them later leave. Read more Singapore · Tax课税范围及其属地逻辑
Singapore income tax is charged under section 10(1) of the Income Tax Act 1947 on income "accruing in or derived from Singapore or received in Singapore from outside Singapore". Read more Singapore · Tax支付型代币：易货、估值与处置
Because IRAS treats a payment token as property and not as money, a payment in tokens is a barter transaction. A business that sells goods for Bitcoin is taxed on the value of the goods supplied. Read more Singapore · Tax贸易标志在加密资产中的适用
The badges of trade are the test IRAS applies to decide whether disposals of tokens are revenue in nature. Read more Singapore · Tax代币发行：发行人所得的ICO款项
The treatment of proceeds from an initial coin offering follows the token type. The Guide's position on each type is one of the more useful statements of Singapore tax practice for a founder. Read more Singapore · Tax空投、硬分叉、质押、挖矿与NFT
The Guide treats each of the common ways of acquiring tokens without payment. Read more Singapore · Tax损失与扣除
Trading losses from token dealing are deductible against other income of the same year under section 37, carried forward indefinitely against future income subject to the shareholding test for… Read more Singapore · Tax新加坡与瑞士所得税处理的比较
The two hubs reach similar results for companies and different results for individuals. Read more Singapore · Tax不课税的原则及其三项限定
Singapore has no capital gains tax. The statement is accurate and is repeated in every pitch deck for a Singapore holding structure, yet it describes an absence in the statute and nothing more. Read more Singapore · Tax交易者与投资者界线的实务
For an individual the line is drawn by the badges of trade and the Comptroller's practice. Read more Singapore · Tax汇入原则：第10(1)条与第10(25)条
Singapore taxes income "received in Singapore from outside Singapore". Read more Singapore · Tax第10L条：2024年以来的境外来源处置收益
Section 10L was inserted by the Income Tax (Amendment) Act 2023 with effect from 1 January 2024 as Singapore's response to the European Union's Code of Conduct Group, which had listed Singapore's… Read more Singapore · Tax第10L条之外的实质要求
Economic substance has become the universal condition of Singapore tax planning, and digital-asset structures feel it from three directions at once. Read more Singapore · Tax与瑞士的对比
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… Read more Singapore · Tax税制概况与2020年的转折点
Singapore's goods and services tax is a value added tax charged under the Goods and Services Tax Act 1993 on supplies of goods and services made in Singapore by a taxable person in the course of… Read more Singapore · Tax消费税法上数字支付代币的定义
The GST definition is narrower than the Payment Services Act definition and narrower than the income tax Guide's notion of a payment token. Read more Singapore · Tax稳定币：不属于DPT定义，但仍享受豁免
The exclusion of currency-pegged tokens from the DPT definition surprises many clients, because a stablecoin is the token most often used as a means of payment. Read more Singapore · Tax兑换服务、中介机构与代理问题
The exemption covers the supply of the token itself. It does not cover the services of the exchange, broker or custodian who makes the transaction possible. Those services remain taxable. Read more Singapore · Tax进项税抵扣与部分豁免
A business that makes both taxable and exempt supplies may recover only the input tax attributable to taxable supplies. Read more Singapore · Tax挖矿、验证与质押服务
Mining is generally not a supply for GST purposes. Read more Singapore · Tax反向征收与瑞士供应商
Since 1 January 2020 Singapore has applied a reverse charge to imported services acquired by businesses that are not entitled to full input tax recovery. Read more Singapore · TaxGST下的NFT与实用型代币
An NFT is not fungible and therefore cannot be a DPT. Its GST treatment depends on what it is. Read more Singapore · TaxGST合规的组织安排
The GST return of a digital-asset business is only as good as the data that feeds it. Read more Singapore · Tax基金税收优惠为何对数字资产至关重要
Singapore's fund industry rests on three statutory exemptions. Read more Singapore · Tax三项计划
Section 13D exempts a non-resident fund that has no presence in Singapore other than its Singapore fund manager. Read more Singapore · Tax指定投资与代币问题
The exemption covers only specified income from designated investments. The designated investments list is set out in the regulations and expanded by successive circulars. Read more Singapore · Tax可变资本公司
The Variable Capital Companies Act 2018 came into force on 14 January 2020 and gave Singapore a fund vehicle built for the purpose. Read more Singapore · Tax基金经理的牌照与税务
A fund manager in Singapore must hold a capital markets services licence for fund management under the Securities and Futures Act 2001 or qualify for an exemption. Read more Singapore · Tax管理新加坡基金的瑞士经理
A Swiss portfolio manager or manager of collective assets licensed under the Financial Institutions Act (FinIA; FINIG) who wishes to manage a Singapore fund has three routes. Read more Singapore · Tax管理瑞士L-QIF的新加坡经理
The reverse case has become possible since 1 March 2024, when the limited qualified investor fund (L-QIF) was introduced into the Collective Investment Schemes Act (CISA; KAG). Read more Singapore · Tax在新加坡基金与瑞士基金之间作选择
The decision depends on investors, strategy and the token problem described above. The following table summarises the points that decide most mandates. Read more Singapore · Tax新加坡家族办公室模式
A single family office in Singapore is a company that manages the assets of one family and nothing else. The structure that MAS and IRAS have in mind has two layers. Read more Singapore · Tax牌照豁免与2023年类别豁免提案
A family office that manages only the assets of a single family does not need a capital markets services licence. Read more Singapore · Tax单一家族办公室的税收优惠条件
Single family office funds obtain their exemption under section 13O or 13U, but the conditions are stricter than for commercial funds and have been tightened twice. Read more Singapore · Tax家族办公室资产配置中的加密资产
The designated investments problem of Chapter IV strikes a crypto family office harder than a commercial fund, because the family's wealth often consists largely of the tokens that made it. Read more Singapore · Tax2023年8月案件与实务收紧
In August 2023 the Singapore Police Force arrested ten foreign nationals and seized or froze assets eventually valued at more than S$ 3 billion in what became the largest money-laundering case in… Read more Singapore · Tax全球投资者计划
The Global Investor Programme, administered by the Economic Development Board, grants permanent residence to investors who commit capital to Singapore. Read more Singapore · Tax与楚格州定额课税的比较
The Singapore family office is often weighed against the Swiss lump-sum regime described in Part G, Chapter VI, although the two instruments are built on different logics. Read more Singapore · Tax以代币作为报酬
Most digital-asset businesses pay part of their people in tokens. Read more Singapore · Tax第10(6)条及适用于代币的股份计划规则
Singapore has a specific regime for employee share plans. Section 10(6) taxes gains from rights to acquire shares, meaning options and share awards, at the time of exercise or vesting. Read more Singapore · Tax视同行权规则与QEEBR递延
Two features of the share plan regime are relevant to a mobile crypto workforce. Read more Singapore · Tax个人的税务居民身份
An individual is resident in Singapore for a year of assessment if he resides in Singapore in the preceding calendar year, except for temporary absences, or if he is physically present or exercises… Read more Singapore · Tax准证制度
Nobody lives and works in Singapore without a pass. The pass system is in practice a filter that decides which founders and employees Singapore wants. Read more Singapore · Tax从瑞士迁往新加坡
A founder who moves from Zug to Singapore faces a sequence of questions on each side. Read more Singapore · Tax从新加坡迁往瑞士
The reverse move is less common but increasingly seen as families return to Europe. Singapore has no exit tax other than the deemed exercise rule, so the founder leaves with his tokens untaxed. Read more Singapore · Tax从保密到自动交换
Singapore and Switzerland were the two financial centres whose bank secrecy the OECD's transparency project was designed to end. Read more Singapore · Tax共同申报准则在新加坡的实施
Singapore implemented the CRS through the Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) Regulations 2016, with due diligence from 1 January 2017 and first… Read more Singapore · Tax加密资产申报框架
CARF requires a Reporting Crypto-Asset Service Provider (RCASP) to identify its users and determine their tax residence. Read more Singapore · TaxCARF对在两个中心均持有资产的客户意味着什么
The arrival of CARF changes the risk profile of three types of client. The first is the Singapore resident with tokens on a Swiss exchange or with a Swiss bank's digital-asset custody. Read more Singapore · Tax新加坡RCASP的义务
A Singapore RCASP must determine whether it is within scope, which for a licensed DPT service provider or DTSP licensee is almost always yes. Read more Singapore · TaxFATCA
Both hubs apply the United States Foreign Account Tax Compliance Act through intergovernmental agreements. Read more Singapore · Tax合规周期与IRAS的信息调取权
Singapore taxes on a preceding-year basis. Income of the calendar year 2025 is assessed in the year of assessment 2026. Individuals file by 18 April. Read more Singapore · Tax罪行与处罚
The Income Tax Act grades its offences by culpability. Section 94 is the general penalty for failing to file or to comply, with a fine up to S$ 5,000 and a penalty of double the tax. Read more Singapore · Tax自愿披露计划
IRAS operates a voluntary disclosure programme that reduces penalties for taxpayers who come forward before IRAS has begun an audit or investigation. Read more Singapore · Tax异议、复核与上诉
A taxpayer who disagrees with an assessment lodges a notice of objection within two months stating the grounds. Read more Singapore · Tax预先裁定
IRAS issues advance rulings on the application of the Income Tax Act to a proposed arrangement under section 108 and the Seventh Schedule. Read more Singapore · Tax逃税作为洗钱的上游犯罪
Since 1 July 2013 serious tax offences have been predicate offences for money laundering under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992. Read more Singapore · Tax与瑞士披露制度的比较
Switzerland offers a penalty-free voluntary disclosure once in a lifetime under Art. 175 para. 3 of the Direct Federal Tax Act, provided the authority has no knowledge of the evasion, the taxpayer… Read more Singapore · Tax协定及其沿革
The Agreement between the Republic of Singapore and the Swiss Confederation for the Avoidance of Double Taxation with respect to Taxes on Income was signed in Singapore on 24 February 2011. Read more Singapore · Tax居民身份与加比规则
A person is resident of a contracting state if he is liable to tax there by reason of domicile, residence, place of management or any similar criterion. Read more Singapore · Tax常设机构
Article 5 defines a permanent establishment as a fixed place of business through which the business of an enterprise is wholly or partly carried on. Read more Singapore · Tax股息、利息与特许权使用费
The treaty reduces Swiss withholding tax on dividends from 35 per cent to 5 per cent where the beneficial owner is a company holding at least 10 per cent of the paying company's capital, and to 15… Read more Singapore · Tax资本利得
Article 13 allocates gains from the alienation of immovable property to the state where the property is situated. Read more Singapore · Tax跨两个中心的受雇所得
Article 15 allocates employment income to the state where the employment is exercised. Read more Singapore · Tax相互协商与信息交换
The mutual agreement procedure is open to a taxpayer who considers that the actions of one or both states result in taxation not in accordance with the agreement. Read more Singapore · Tax写给必须作出决定的读者：结语比较
This Part has shown a tax system that is generous to the investor, demanding of the trader, indifferent to the token as such and increasingly insistent on substance. Read more