Ireland vs South Africa
Crypto regulation comparison
Ireland
South Africa
Cryptocurrency is legal in Ireland and subject to a 33% capital gains tax, one of the higher rates in the EU. The Central Bank of Ireland supervises VASPs under AML regulations, and Ireland follows the EU's MiCA framework. Ireland's status as a European tech hub has attracted crypto businesses.
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
- 33% capital gains tax on crypto profits (CGT), with an annual exemption of €1,270
- Income from crypto mining, staking, or airdrops may be treated as income tax
- Central Bank of Ireland registers VASPs under the Criminal Justice (Money Laundering) Act
- MiCA framework applicable from December 2024
- Ireland hosts European headquarters of several major crypto firms
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