By: Jeremy O’Neill
23 Sep 2026 6 min read
On 1 September 2026, the Monetary Authority of Singapore (MAS) published its long-awaited consultation on amendments to the Payment Services Act 2019 to bring its stablecoin framework into force.
For product and treasury teams, the headlines are significant: a dedicated stablecoin issuance licence, full reserve backing, redemption at par, a prohibition on paying interest to holders and, for the first time, a pathway for multi-jurisdictional issuance and recognition of foreign-issued stablecoins. Submission of consultation comments close on 16 October.
What the headlines do not cover is how any of this affects the GST landscape. In our experience, that is where the regulatory label starts to do less work than many businesses expect.
Under the draft amendments, stablecoins are treated as a subset of digital payment tokens (DPTs) for Payment Services Act purposes and are expressly carved out of e-money. Stablecoins that do not carry the “MAS-regulated” label remain lawful and continue to be regulated as DPTs.
It is natural to assume GST follows the same map. At present, it does not. IRAS’s e-Tax Guide on digital payment tokens, refreshed in January 2026, still states that a token pegged to a fiat currency (i.e. stablecoins) does not meet the GST definition of a digital payment token (DPT). IRAS instead treats fiat-pegged tokens as derivatives, which are exempt under a different legislative provision.
In straightforward cases the headline outcome may look similar. But the route matters. The GST rules written specifically for DPTs – including the rule that disregards the use of a DPT as payment – are framed around the GST definition which does not include stablecoins, rather than the MAS one.
In short, the “DPT” label a compliance team uses every day and the classification a GST return relies on are not the same thing. Whether IRAS revisits its position as the MAS legislation takes shape is something we are watching closely.
The token is rarely the whole business. MAS has been clear that stablecoins are payment instruments, not savings products, which is why issuers will be prohibited from paying interest on holdings. Commercially, reserve income becomes the core engine, with minting and redemption fees, custody, integration and technology services sitting around it. We regularly see models where the token supply itself is exempt, but a meaningful share of revenue may not be – and where that split has never been deliberately mapped. As we noted in the first article in this series, one payment journey can raise many GST questions; a stablecoin model is no different.
Distribution arrangements multiply the questions. MAS has indicated the interest prohibition is not intended to disturb commercial arrangements between issuers and third parties such as distributors and exchanges. Those arrangements are exactly where GST complexity builds: who is supplying what to whom, whether a payment is consideration for a service, and where the recipient belongs. For issuers or proprietary traders making largely exempt supplies, fees paid to overseas partners can also bring the GST reverse charge provisions into play.
Compliance cost meets limited recovery. A business built around exempt token supplies or exempt reserve income will often have restricted input tax recovery. At the same time, the proposed requirements add cost: reserve custody, attestation and audit, quarterly stress testing, recovery and wind-down planning, and the technical capability to trace, freeze or burn tokens. Businesses are often surprised by how much of that spend carries irrecoverable GST, and how early the partial exemption methodology needs to be settled.
New structures create new flows. Banks wishing to issue MAS-regulated stablecoins may need to do so through a separate non-bank licensed entity. Multi-jurisdictional issuance involves affiliated issuers sharing a common reserve pool, supported by attribution models and rebalancing arrangements. Each creates intercompany charges – for technology, treasury, reserve management and shared services – that need a GST analysis alongside the transfer pricing one.
It is not only an issuer question. Exchanges, wallet providers and merchants that accept, hold or pay third parties with stablecoins face their own classification and reporting questions, particularly given the definitional gap above. We will look at the service layer around digital assets in more detail in the next article in this series.
For businesses launching, distributing or integrating stablecoins, the areas we would typically look at first include:
If the MAS, the IRAS and our external auditors each asked us to describe our stablecoin, and the revenue it generates, in a single paragraph – would all three receive the same answer?
Singapore’s framework is taking shape alongside regimes in the United States, the European Union, the United Kingdom and Hong Kong, and MAS has said it will consult separately on the subsidiary legislation that will carry much of the operational detail. Product teams are moving quickly.
In our experience, the businesses that bring tax, finance and control teams into the design conversation early are the ones that avoid expensive restructuring later.
Grant Thornton Singapore’s Indirect Tax team works with payment, stablecoin and digital asset businesses to map token design and revenue streams to their GST touchpoints, model input tax recovery and build the evidence and tax-coding logic that supports those positions.
Alongside our Business Risk Solutions colleagues, we also support MAS compliance gap assessments, product governance reviews and launch-readiness work, so that regulatory, tax and control questions are addressed together.
If the consultation has prompted questions about your own model, we would be glad to talk them through.
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