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Bulgaria vs South Africa

Crypto regulation comparison

← Back to map | Bulgaria | South Africa
Bulgaria

Bulgaria

South Africa

South Africa

Legal
Legal

Cryptocurrency is legal in Bulgaria and subject to a flat 10% tax on capital gains, one of the lowest in the EU. Bulgaria adopted the EU's MiCA framework and requires crypto service providers to register. The country has a notable history with crypto due to a large government Bitcoin seizure in 2017.

South Africa has embraced crypto regulation. In 2022, the FSCA declared crypto assets as financial products under the Financial Advisory and Intermediary Services (FAIS) Act, requiring crypto service providers to obtain FSCA licenses. SARS taxes crypto gains under capital gains tax (up to 18% effective rate for individuals) or income tax depending on trading frequency. South Africa is the largest crypto market in Africa.

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 10%
Tax Rate 18% (effective max ~18%)
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining No No
Regulator NRA (National Revenue Agency), FSC (Financial Supervision Commission)
Regulator FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules Regulated under EU MiCA framework
Stablecoin Rules Crypto assets declared financial products under FAIS; stablecoins included
Key Points
  • Flat 10% personal income tax rate applies to crypto capital gains
  • VASPs must register with the NRA for AML compliance
  • MiCA framework applicable from December 2024
  • Bulgaria reportedly seized approximately 200,000 BTC in a 2017 crime bust (status debated)
  • No specific crypto legislation beyond EU directives and general tax law
Key Points
  • Crypto declared a financial product under FAIS Act (2022); service providers must be FSCA-licensed
  • FSCA began licensing crypto asset service providers (CASPs) in 2023
  • Capital gains taxed at effective rate up to 18% (45% max marginal rate × 40% inclusion)
  • Frequent trading may be classified as income and taxed at marginal rates (up to 45%)
  • SARB regulates cross-border crypto transactions under exchange control regulations
Sources
Sources