Lithuania vs South Africa
Crypto regulation comparison
Lithuania
South Africa
Cryptocurrency is legal and regulated in Lithuania. The Bank of Lithuania oversees VASPs under AML regulations and has been an early mover in crypto regulation within the EU. Lithuania attracted a large number of VASP registrations due to initially favorable conditions, though it tightened requirements significantly in 2022-2023. The MiCA framework now applies.
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
- VASPs must register with the Bank of Lithuania under AML/CFT law
- Capital gains from crypto taxed at 15% personal income tax rate
- Lithuania became a major EU hub for crypto companies; over 500 VASPs registered by 2022
- Tightened VASP requirements in 2022-2023, including local substance and capital requirements
- MiCA transition underway from December 2024
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