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Denmark vs South Africa

Crypto regulation comparison

← Back to map | Denmark | South Africa
Denmark

Denmark

South Africa

South Africa

Legal
Legal

Cryptocurrency is legal in Denmark and regulated under EU frameworks including MiCA. Denmark has notably high tax rates on crypto gains, treated as personal income and taxed at rates up to 52%. The Danish Tax Council confirmed in 2018 that gains and losses on Bitcoin are taxable.

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 37-52%
Tax Rate 18% (effective max ~18%)
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining No No
Regulator Finanstilsynet (Danish FSA), Skattestyrelsen
Regulator FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules Regulated under EU MiCA framework (Denmark is EU member but outside eurozone)
Stablecoin Rules Crypto assets declared financial products under FAIS; stablecoins included
Key Points
  • Crypto gains taxed as personal income at 37-52% (among the highest in the world)
  • Losses on crypto can be deducted against gains
  • Finanstilsynet supervises crypto businesses under the Danish AML Act
  • Denmark does not have its own crypto-specific legislation beyond EU frameworks
  • Skattestyrelsen (tax authority) actively monitors crypto transactions and issues guidance
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
Sources
Sources