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Switzerland vs South Africa

Crypto regulation comparison

Switzerland

Switzerland

South Africa

South Africa

Legal
Legal

Switzerland is one of the world's most crypto-friendly jurisdictions. The Canton of Zug is known as 'Crypto Valley' and hosts the Ethereum Foundation and hundreds of blockchain companies. FINMA provides clear regulatory guidance, and the DLT Act (2021) created a legal framework for tokenized securities and crypto exchanges. Individual investors pay no capital gains tax on crypto, though it is included in the cantonal wealth tax base. Professional traders may be subject to income tax.

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 Wealth
Tax Type Capital gains
Tax Rate 0% capital gains (individuals); wealth tax varies by canton
Tax Rate 18% (effective max ~18%)
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining No No
Regulator FINMA (Swiss Financial Market Supervisory Authority)
Regulator FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules Regulated under FINMA framework; fiat-pegged stablecoin issuers must hold a banking or fintech licence (reserves treated as public deposits), or a payment system licence under FMIA if structured as financial market infrastructure
Stablecoin Rules Crypto assets declared financial products under FAIS; stablecoins included
Key Points
  • No capital gains tax on crypto for individual investors (private wealth management)
  • Crypto included in cantonal wealth tax base (rates vary by canton, typically 0.1-1%)
  • Professional/frequent traders may be classified as self-employed and taxed on income
  • FINMA regulates crypto under existing financial market laws and the 2021 DLT Act
  • DLT Act (2021) introduced DLT trading facility license and legal framework for tokenized assets
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