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Bahrain vs South Africa

Crypto regulation comparison

← Back to map | Bahrain | South Africa
Bahrain

Bahrain

South Africa

South Africa

Legal
Legal

Bahrain is one of the most crypto-friendly jurisdictions in the Middle East. The Central Bank of Bahrain introduced a comprehensive crypto-asset regulatory framework in 2019, and there is no personal income or capital gains tax. Several major exchanges including Binance have obtained licenses.

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 No tax
Tax Type Capital gains
Tax Rate 0%
Tax Rate 18% (effective max ~18%)
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining No No
Regulator CBB (Central Bank of Bahrain)
Regulator FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules Regulated under CBB crypto-asset module; stablecoin issuance requires CBB licensing
Stablecoin Rules Crypto assets declared financial products under FAIS; stablecoins included
Key Points
  • CBB Crypto-Asset Module provides a full regulatory framework for exchanges, custodians, and brokers
  • No personal income tax or capital gains tax in Bahrain
  • Licensed exchanges include Binance (CoinMENA), Rain, and others
  • VASPs must meet AML/CFT requirements and obtain CBB licensing
  • Bahrain positions itself as a regional fintech and crypto hub
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