China vs South Africa
Crypto regulation comparison
China
South Africa
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.
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