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China vs South Africa

Crypto regulation comparison

China

China

South Africa

South Africa

Banned
Legal

China has imposed a comprehensive ban on cryptocurrency activities. In September 2021, the PBOC and ten other agencies jointly declared all cryptocurrency transactions illegal, and the State Council banned crypto mining. China is instead promoting the digital yuan (e-CNY) CBDC.

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 Unclear
Tax Type Capital gains
Tax Rate N/A
Tax Rate 18% (effective max ~18%)
Exchanges No No
Exchanges Yes Yes
Mining No No
Mining No No
Regulator PBOC (People's Bank of China), CBIRC, CSRC
Regulator FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules Not applicable; all crypto activities are banned
Stablecoin Rules Crypto assets declared financial products under FAIS; stablecoins included
Key Points
  • All crypto transactions declared illegal by PBOC and 10 agencies in September 2021
  • Crypto mining banned by the State Council in 2021 after a series of provincial crackdowns
  • Financial institutions and payment companies prohibited from facilitating crypto services
  • China actively developing and piloting the digital yuan (e-CNY) CBDC
  • Despite the ban, some Chinese citizens reportedly access crypto via VPNs and OTC desks
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