Marshall Islands vs South Africa
Crypto regulation comparison
Marshall Islands
South Africa
The Marshall Islands passed the Sovereign Currency Act in 2018 to create the SOV, a blockchain-based national digital currency. No income or capital gains tax.
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
- Sovereign Currency Act (2018) created SOV digital currency
- No income or capital gains tax
- Has been a popular jurisdiction for DAO registration
- Banking Commission provides oversight
- Limited domestic crypto adoption
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