Norway vs South Africa
Crypto regulation comparison
Norway
South Africa
Cryptocurrency is legal in Norway and regulated by Finanstilsynet. Norway taxes crypto capital gains at 22% and includes crypto holdings in the annual wealth tax calculation (net wealth above NOK 1.7M taxed at ~1.1%). VASPs must register with Finanstilsynet. Norway is an EEA member and aligning with MiCA through the EEA agreement.
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
- Crypto capital gains taxed at 22% flat rate
- Crypto included in wealth tax base (~1.1% on net wealth above threshold)
- VASPs must register with Finanstilsynet and comply with AML/CFT requirements
- Norway is a major crypto mining hub due to cheap hydroelectric power
- EEA member; MiCA implementation expected through EEA Agreement adaptation
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