Saudi Arabia vs South Africa
Crypto regulation comparison
Saudi Arabia
South Africa
Saudi Arabia has an ambiguous but generally restrictive approach to cryptocurrency. SAMA has not licensed any crypto exchanges, and financial institutions are warned against dealing in crypto. However, crypto is not explicitly banned by law, and Saudi Arabia has participated in blockchain initiatives (Project Aber with the UAE central bank). No personal income or capital gains tax exists in Saudi Arabia.
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
- SAMA has not authorized or licensed any cryptocurrency exchanges
- Financial institutions warned against crypto transactions
- Crypto not explicitly banned but not regulated; exists in a legal gray area
- No personal income or capital gains tax in Saudi Arabia
- Saudi Arabia participated in CBDC experiments (Project Aber with UAE)
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