By: Jeremy O’Neill
22 Oct 2026 5 min read
The commercial reality is broader. Exchanges, wallet providers and custodians typically earn from trading fees, spreads, custody and safekeeping charges, withdrawal fees, listing and onboarding fees, API access and, increasingly, arrangements with token issuers.
The token is one line in that mix and, while their analysis can be complex, it is rarely the area that generates the most GST questions.
The GST treatment of digital payment tokens (DPTs) has been settled in Singapore since 2020: exchanging DPTs for fiat currency or other DPTs is exempt, while services provided by intermediaries remain taxable.
The IRAS’s DPT e-Tax Guide, now in its third edition (January 2026), remains the reference point. As we discussed in our previous article 'Stablecoins and digital currencies: why the label is only the starting point', labels only go so far. IRAS’s guide, for example, treats fiat-pegged tokens (i.e. stablecoins) differently from DPTs, even though MAS’s draft legislation would treat stablecoins as a subset of DPTs for regulatory purposes.
What is changing is the environment around it. On 1 September, MAS published a consultation paper on legislation to implement its stablecoin framework. Most of the commentary has focused on issuers, but several proposals reach the platform layer.
MAS is considering additional disclosure and marketing requirements for licensed DPT service providers offering non-MAS-regulated stablecoins to retail customers, and the draft would allow it to direct platforms to delist a stablecoin designated as systemic.
Issuers would be barred from paying interest to holders, although the proposals are not intended to disturb revenue-sharing and distribution arrangements with third parties. Meanwhile, Visa’s decision to join MAS’s BLOOM initiative in August is a further sign of card and payment networks testing regulated stablecoins for settlement.
These developments do not change the GST rules, but they do change what platforms sell, to whom and how they are paid, and GST follows the revenue model.
The exempt token leg gets applied to everything around it. Businesses are often surprised by how many fee lines sit alongside a token exchange without being the exchange itself. Spreads, commissions, custody charges and withdrawal fees can each raise a different question, particularly when they are bundled into a single price or a tiered fee schedule.
Principal or agent is answered once, then forgotten. The answer affects what is reported as the platform’s own supply and what is reported as a fee or margin. We regularly see it settled at launch and not revisited when the business adds an OTC desk, a liquidity partner or a new custody arrangement. The contracts move on; the GST position often does not.
Fees collected in tokens. When a platform is paid in tokens, questions follow on valuation, rate sources and timing. questions arise around valuation, rate sources and timing. The IRAS’s guide offers some flexibility, but consistency matters, and we frequently find that the timestamps in the trading system, the ledger and the GST return do not agree.
Customer location is an evidence question. Where a Singapore entity serves overseas users, the guide describes a proxy approach based on payment, residence and access data. If that evidence cannot be produced, the default assumption is that the customer belongs in Singapore. In practice, the data often sits in compliance systems that finance rarely sees.
Partial exemption arrives quietly. Exempt token income alongside taxable service fees makes input tax attribution and reverse charge live issues, particularly on cloud, security and overseas vendor spend. Where a business sits on the spectrum, from token trading as its core activity to something more incidental, depends on the facts, and it is a question we often see answered by assumption.
Issuer arrangements are new territory. Revenue-share, distribution and listing arrangements with stablecoin issuers are starting to appear, often with overseas counterparties, and often signed before anyone has asked how the income should be treated for GST.
There is rarely a single answer to these questions, and outcomes depend on the facts. Areas that require a closer look include:
If the IRAS asked us to trace a single withdrawal fee from the customer’s wallet to the GST return, could we do it, and would finance, operations and compliance give the same answer?
Our indirect tax team and our Business Risk Solutions colleagues increasingly work side by side on exactly this join: where tax classification meets custody, settlement and wallet-access controls, and the data that connects them.
With the consultation and subsidiary legislation to follow, we find that early conversations about how the revenue model, contracts and controls fit together tend to produce better commercial outcomes than retrofitting them later. If any of this sounds familiar, we would be glad to compare notes.
In this article, we explore how stablecoin and digital currency businesses can assess GST treatment, revenue streams and input tax recovery amid Singapore’s evolving regulatory framework.
In this article, we explore how cross-border payment businesses can assess customer location, operating substance and supporting evidence to strengthen GST positions and regulatory readiness.
In this article, we explore why payment businesses need transaction mapping to identify GST risks and compliance gaps.
