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Canada vs South Africa

Crypto regulation comparison

Canada

Canada

South Africa

South Africa

Legal
Legal

Canada has a well-developed regulatory framework for cryptocurrency. Crypto trading platforms must register with provincial securities regulators through the CSA, and all crypto businesses must register as money services businesses (MSBs) with FINTRAC. Canada approved spot Bitcoin ETFs in 2021, ahead of most other countries.

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 0-26.76%
Tax Rate 18% (effective max ~18%)
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining No No
Regulator CSA, FINTRAC, OSC, AMF
Regulator FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules CSA guidance requires stablecoins to maintain adequate reserves; value-referenced crypto assets regulated
Stablecoin Rules Crypto assets declared financial products under FAIS; stablecoins included
Key Points
  • Crypto trading platforms must register with CSA provincial regulators
  • All crypto dealers must register as MSBs with FINTRAC for AML/KYC compliance
  • 50% of capital gains are taxable; business income from crypto is fully taxable
  • Canada approved spot Bitcoin and Ether ETFs in 2021, the first major country to do so
  • CSA issued Staff Notice 21-327 on obligations for crypto trading platforms
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