Compare

Two modes: multiple activities in one jurisdiction, or multiple jurisdictions for one activity.

Data last reviewed: April 2026

Pick 1 activity and 2–5 jurisdictions and compare regimes, costs and timelines.

Operations / services(8)
Token issuance(7)
Financial services(2)
Applications(3)

3 jurisdictions compared for RWA — Real-World Asset Tokenisation

i
Tax treatment

Tax summary per jurisdiction (shared across all activities). General information, not tax advice.

🇫🇷France

Individuals: 30% PFU flat tax (12.8% IR + 17.2% social) on occasional gains; pro traders taxed as BIC/BNC. Mining: BNC. Crypto-to-crypto = non-taxable until fiat-conversion.

🇦🇪UAE / Dubai

NO personal income tax on crypto for individuals. Companies: 9% corporate tax on profits > AED 375K (since June 2023). VAT exempt on crypto transfers (Nov 2024).

🇸🇬Singapore

NO capital-gains tax. Trading as business: 17% corporate income tax. GST exempt on payment tokens (since 2020). Personal income only if classified as business income.

Field
🇫🇷France
🇦🇪UAE / Dubai
🇸🇬Singapore
Applicable Regime
The legal text that grounds it all — scope & territorial reach
📜ADGM
Risk Level
How critical non-compliance is for your activity
HighMediumMedium
OUTPUTS — What you must do
Licences Required
The concrete authorizations you must obtain
  • Capital Markets Services licence
  • Recognized Market Operator (if exchange)
Key Obligations
Daily compliance duties (KYC, AML, Travel Rule…)
  • Prospectus requirements
  • KYC/AML
  • Custody of underlying assets
  • SFA prospectus
  • KYC/AML
  • Ongoing disclosure
CONTEXT — When, how much, with whom
Estimated Timeline
How long to obtain the licence + go live
12–24 months6–12 months6–18 months
Estimated Cost
Licence fees + capital + ongoing costs
€100K–€500K+$75K–$250KSGD 100K–400K
Regulator
The body that supervises and issues the licence
🏛️ESMA🏛️AMF🏛️NCAFSRA ADGM / DFSA DIFC🏛️MAS
XRPL-Specific Note
How this plays out on XRPL specifically
XRPL supports RWA tokenisation via IOU/Trust Lines (existing) or MPT XLS-33 (programmable compliance flags). Escrow enables delivery-vs-payment. Trust Line freeze flags provide compliance enforcement.

🏛️ Official portals by jurisdiction

Regulators, public registers and law texts to verify directly at the source. Opens in a new tab.

🗺️Arbitrage map — speed vs cost

Where does each jurisdiction sit on the speed × cost axis? Dot size = market access, colour = risk. Find your sweet spot.

0m6m12m18m24m30m36mTime to licence (months)10K50K100K500K1000KSetup cost (€, log scale)Fast & expensiveSlow & expensive⭐ Fast & cheapSlow & cheap🇱🇮Liechtenstein🇨🇭Switzerland🇦🇪UAE / Dubai🇸🇬Singapore🇬🇧United Kingdom🇪🇺EU (MiCA)🇭🇰Hong Kong🇺🇸USA🇧🇷Brazil🇯🇵Japan
Risk level (dot color)
Low — progressive regime (TVTG, FINMA)
Medium — structured but friendly (VARA, MAS, FCA)
High — strict or fragmented (MiCA, SFC, US)
Market access (dot size)
Narrow — single country
Wide — region or hub
Huge — EU-27 passport or US national
⭐ Fast & cheap quadrant

Liechtenstein TVTG, Brazil, Switzerland. Ideal starting points when budget and time are the top constraints. Liechtenstein adds EEA passporting as a bonus.

🚀 Fast & structured

Dubai VARA, Singapore MAS. Modern rulebooks, ~9 months, 50-150K€. Strong pick for global operators who want a credible first licence.

🏛 Slow & expensive

US state MTLs, EU MiCA, Hong Kong SFC. Required for access to the biggest markets. Plan capital and 12-24 months; passport or stack once approved.

Ready to pick one?

The diagnostic walks you through speed / cost / market / reputation priorities and outputs a recommended jurisdiction.

Which jurisdiction should I choose?

General information only. For your specific situation, consult a qualified lawyer.