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France vs South Africa

Crypto regulation comparison

← Back to map | France | South Africa
France

France

South Africa

South Africa

Legal
Legal

France has one of Europe's most developed crypto regulatory frameworks. The PACTE law (2019) established the PSAN (prestataire de services sur actifs numériques) registration regime, now transitioning to MiCA licensing. Crypto gains are subject to the 30% flat tax (prélèvement forfaitaire unique).

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 30%
Tax Rate 18% (effective max ~18%)
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining No No
Regulator AMF (Autorité des Marchés Financiers), ACPR
Regulator FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules Regulated under MiCA; stablecoin issuers need e-money or credit institution license
Stablecoin Rules Crypto assets declared financial products under FAIS; stablecoins included
Key Points
  • 30% flat tax on crypto capital gains (12.8% income tax + 17.2% social charges) for non-professionals
  • PSAN registration required by AMF for all crypto service providers (mandatory since 2023)
  • Transitioning from PSAN regime to MiCA licensing framework in 2024-2025
  • Professional crypto traders may opt for progressive income tax rates
  • France is home to major crypto companies including Ledger and Société Générale's FORGE
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