Singapore: crypto taxes when leaving Germany

• Disposal and exchange: No capital gains tax. Gains generally stay tax-free for private investors, regardless of holding period or amount; FIFO, LIFO, or average price are irrelevant for this.
• Commercial classification: Anyone trading regularly, on a large scale, and with a recognizably business-like character risks being reclassified as a taxable trade or business under the “badges of trade” (among others trading frequency, holding period, financing structure, purpose of the acquisition). IRAS accepts FIFO and the weighted average price, but not LIFO; records must be kept for five years.
• Airdrops, hard forks, mining: Airdrops received without consideration and tokens from a hard fork count as a windfall and aren't taxable on receipt. IRAS initially treats mining by private individuals as a hobby; only once a systematic, profit-oriented activity becomes apparent is it business income, taxable at the time of disposal.
• Staking, lending, liquidity mining: There's no dedicated guidance so far; the badges of trade decide. Occasional staking through an exchange generally stays untaxed for private investors, while operating validator infrastructure of one's own can be captured as business income at up to 24 %.
• Crypto as compensation: Salary or compensation in crypto assets is regular income, taxed at market value at the time of receipt.
• GST: Since 1 January 2020, supplies of digital payment tokens have been exempt from Goods and Services Tax (exchange for fiat money or other payment tokens, lending in such tokens).
• Wealth and inheritance: No wealth tax, no inheritance tax (abolished in 2008).

Year of departure

• German unlimited tax liability only ends once residence and habitual abode are actually given up.
• In Singapore, tax residency arises for a foreigner staying in the country for at least 183 days in the tax year, or working there continuously for at least three years, even if the length of stay in individual years is under 183 days.
• If the German home has already been given up at the time of a crypto sale, the gain isn't domestic income under § 49 EStG. If both homes exist in parallel, the tie-breaker under the DTT applies: permanent home, then center of vital interests, then habitual abode.
• The § 2 AStG check is relevant if a German salary, rental income, or a larger portfolio remains; it is also disputed whether such gains would even be captured by § 2 AStG as “non-foreign income”.

First year after leaving

• Example: Ms. Lindqvist (Hamburg to Singapore in 2026, home given up, no longer working for her German employer) sells Bitcoin at a significant gain: § 2 AStG isn't a consideration for her, and in Singapore the gain is tax-free. Mr. Brandt (German consulting fee, rented property in Germany) should run the calculation specifically.
• A commercial crypto history from Germany isn't carried over but reassessed; it can be taken as an indication if the activity is continued in Singapore on a similar scale.

More than ten years

• In Singapore, nothing changes over time for income tax purposes. On the German side, if Singapore is classified as a low-tax country, extended limited tax liability can apply in the first years; it ends ten years after the end of the year in which German unlimited tax liability ended. From then on, only ordinary limited tax liability remains, which requires a domestic source of income (current position).
• No inheritance tax treaty: for German nationals, German extended unlimited inheritance tax liability applies if the deceased or donor was fully taxable in Germany within the last five years before the inheritance; after more than ten years, this window is closed.
• Singapore is one of the most expensive cities in the world; a permanent residence permit (Employment Pass with COMPASS; for very wealthy individuals, the Global Investor Programme) isn't a given.

Moving on to a third country

• Singapore has no exit taxation for privately held crypto assets, for lack of a general capital gains tax. Any extended limited tax liability under § 2 AStG is reassessed annually; if a person moves, within the ten-year period, to a country that isn't itself a low-tax country, it can cease to apply for that period.

Returning to Germany

• Moving back automatically ends any extended limited tax liability; unlimited tax liability applies again. The original acquisition cost and acquisition date remain decisive; if a position has been held for longer than a year in total, a later sale in Germany is tax-free under § 23 EStG.