Georgia vs South Africa
Crypto regulation comparison
Georgia
South Africa
Georgia is one of the most crypto-friendly countries globally. There is no capital gains tax for individuals on cryptocurrency, and the country has a significant crypto mining industry due to low electricity costs. The National Bank has taken a cautious but permissive approach, issuing guidance rather than strict regulation.
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
- No capital gains tax on crypto for individuals
- Businesses dealing in crypto are taxed under standard corporate tax rules (15% CIT)
- Georgia is a major crypto mining hub due to cheap hydroelectric power
- NBG does not recognize crypto as legal tender but has not prohibited it
- The Free Industrial Zone offers additional tax advantages for crypto businesses
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