Liechtenstein vs South Africa
Crypto regulation comparison
Liechtenstein
South Africa
Legal
Legal
Liechtenstein's Blockchain Act (TVTG) effective since 2020 is among the world's most comprehensive crypto frameworks. The FMA supervises registered TT service providers. Adapted for EU MiCAR in 2025.
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
Income
Tax Type
Capital gains
Tax Rate
1-8%
Tax Rate
18% (effective max ~18%)
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
No
Regulator
Financial Market Authority (FMA)
Regulator
FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules
Regulated under TVTG and MiCAR
Stablecoin Rules
Crypto assets declared financial products under FAIS; stablecoins included
Key Points
- Blockchain Act (TVTG) adopted unanimously in 2019, effective Jan 2020
- Token Container Model enables tokenization of any asset or right
- FMA registers and supervises all TT service providers
- EEA MiCAR Implementation Act entered into force Feb 2025
- First country with comprehensive blockchain-specific legislation
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