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Greece vs South Africa

Crypto regulation comparison

Greece

Greece

South Africa

South Africa

Legal
Legal

Cryptocurrency is legal in Greece and regulated under the EU framework. A 2024 tax reform established a 15% tax on crypto capital gains, replacing the prior uncertain treatment. The Hellenic Capital Market Commission oversees crypto service provider registration.

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 15%
Tax Rate 18% (effective max ~18%)
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining No No
Regulator HCMC (Hellenic Capital Market Commission), Bank of Greece
Regulator FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules Regulated under EU MiCA framework
Stablecoin Rules Crypto assets declared financial products under FAIS; stablecoins included
Key Points
  • 15% capital gains tax on crypto established under recent tax reforms
  • HCMC registers and supervises crypto service providers
  • Greece adopted EU AML directives for crypto businesses
  • MiCA framework applicable from December 2024
  • Crypto adoption grew during the 2015 financial crisis and capital controls
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