Tonga vs South Africa
Crypto regulation comparison
Tonga
South Africa
No Regulation
Legal
Tonga has no specific cryptocurrency regulation. There has been legislative interest in adopting Bitcoin as legal tender but no legislation has been enacted.
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
None
Tax Type
Capital gains
Tax Rate
N/A
Tax Rate
18% (effective max ~18%)
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
No
Regulator
National Reserve Bank of Tonga
Regulator
FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules
No stablecoin regulation
Stablecoin Rules
Crypto assets declared financial products under FAIS; stablecoins included
Key Points
- No specific cryptocurrency legislation
- Legislative interest in Bitcoin legal tender discussed
- National Reserve Bank provides monetary oversight
- Limited crypto infrastructure
- No licensing framework for crypto services
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