Bhutan vs South Africa
Crypto regulation comparison
Bhutan
South Africa
Legal
Legal
Bhutan has quietly become a significant Bitcoin miner through its government investment arm, Druk Holding & Investments, leveraging hydroelectric power. No tax on crypto.
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
Exchanges
Yes
Mining
Yes
Mining
No
Regulator
Royal Monetary Authority of Bhutan
Regulator
FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules
No specific stablecoin regulation
Stablecoin Rules
Crypto assets declared financial products under FAIS; stablecoins included
Key Points
- Government entity Druk Holding & Investments mines Bitcoin
- Hydroelectric power used for mining operations
- No income or capital gains tax in Bhutan
- Royal Monetary Authority provides oversight
- One of the few countries with state-level crypto mining operations
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