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El Salvador vs South Africa

Crypto regulation comparison

← Back to map | El Salvador | South Africa
El Salvador

El Salvador

South Africa

South Africa

Legal
Legal

El Salvador made history in September 2021 by becoming the first country to adopt Bitcoin as legal tender through the Bitcoin Law. However, under a January 2025 IMF agreement (Decreto 199), El Salvador amended the law to make Bitcoin acceptance by businesses voluntary rather than mandatory, and repealed several articles. There is no capital gains tax on Bitcoin. The CNAD regulates digital assets.

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 No tax
Tax Type Capital gains
Tax Rate 0%
Tax Rate 18% (effective max ~18%)
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining No No
Regulator BCR (Banco Central de Reserva), CNAD (Comisión Nacional de Activos Digitales)
Regulator FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules USD is the primary currency; Bitcoin-specific legislation in place
Stablecoin Rules Crypto assets declared financial products under FAIS; stablecoins included
Key Points
  • First country to adopt Bitcoin as legal tender in September 2021 via the Bitcoin Law
  • Government developed the Chivo wallet for citizens, offering $30 USD in BTC incentive
  • January 2025 Decreto 199 made merchant Bitcoin acceptance voluntary (IMF condition)
  • No capital gains tax on Bitcoin transactions for individuals
  • Government has been accumulating Bitcoin reserves and launched Bitcoin-backed bonds
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
Sources
Sources