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SARS’ Crypto dragnet: how the tax net Is closing on South Africa’s digital wealth

Willem J. Oberholzer|Published

Crypto wallets, offshore trading accounts and cross-border digital wealth will now feed into the same international transparency grid that already tracks traditional bank accounts.

Image: File.

From 1 March 2026, one of the predicted fundamental changes in South Africa’s tax landscape, according to media releases, will come into effect. Not the rates. Not the law. The visibility.

The South African Revenue Service (SARS) is integrating the OECD’s Crypto-Asset Reporting Framework (CARF) into its enforcement architecture, alongside an enhanced Automatic Exchange of Information (AEOI) regime.

In practical terms, this means crypto wallets, offshore trading accounts and cross-border digital wealth will now feed into the same international transparency grid that already tracks traditional bank accounts.

For years, there has been a quiet assumption in parts of the digital economy that complexity creates obscurity. Multiple wallets. Foreign exchanges. Layered offshore structures. Decentralised finance platforms. The belief was not always that crypto was untaxed, but rather that it was difficult to trace.

That assumption is imploding.

From guesswork to data symmetry

SARS has never regarded crypto gains as tax-free. The Income Tax Act has always been clear: residents are taxed on worldwide income. If crypto is held as trading stock, gains fall into revenue and are taxed at marginal rates. If held as a capital asset, the Eighth Schedule applies, and capital gains tax follows. The legal position has not shifted; what has shifted is the enforcement capability.

Under CARF, crypto-asset service providers will collect and transmit detailed user and transaction information in a standardised format designed specifically for automated exchange between tax authorities.

Account identifiers, transaction histories, disposals, conversions and transfers are no longer isolated pieces of data. They become structured inputs in a global reporting system.

At the same time, South Africa’s existing participation in the Common Reporting Standard (CRS) continues to feed offshore financial account data into SARS’ systems. Crypto is now being plugged into that same matrix. The result is not louder rhetoric. It is quieter, more precise detection.

Where SARS once had to infer lifestyle mismatches or rely on sporadic disclosures, it will increasingly be able to reconcile declared income against transaction-level data. Algorithms do not rely on suspicion; they rely on comparison.

The classification trap

One of the most misunderstood areas in crypto taxation is classification.

Many taxpayers assume that crypto gains are automatically treated as capital gains. They are not. The determination turns on intention, frequency, scale and conduct.  Simply put, it is the same principles that have governed share trading and property transactions for decades.

An individual who trades actively, rotates positions, arbitrages price movements or uses leverage may find those gains treated as revenue, fully taxable at marginal rates up to 45%. A long-term investor holding Bitcoin as a strategic store of value may fall within capital gains tax. The distinction is factual, not elective.

In an environment of limited data, classification disputes could be protracted and evidentially complex.

In an environment where SARS receives structured transaction histories, inconsistencies become easier to identify and harder to defend. 

Incorrect classification is no longer merely a technical risk. It is a measurable exposure.

Offshore is not outside the system

A second misconception lies in the use of offshore exchanges and foreign entities. Many South Africans fund foreign crypto accounts through approved foreign investment allowances or, in some cases, without full exchange control alignment.

What is often overlooked is that South Africa already participates in a multilateral exchange of financial information. Foreign financial institutions report into global systems that SARS can access. With crypto reporting layered into that architecture, offshore wallets no longer sit beyond meaningful visibility.

Add to this the fact that residents are taxed on worldwide income, and the comfort historically associated with “foreign” accounts becomes fragile.

For those who externalised funds without proper exchange control approval, or who failed to declare offshore crypto gains, the risk is twofold: tax exposure and potential regulatory contraventions.

The penalty environment

The Tax Administration Act places the burden of proof squarely on the taxpayer. If SARS raises an assessment based on third-party data, it is the taxpayer who must demonstrate that it is incorrect.

Understatement penalties can range from 10% to 150%, depending on the behaviour involved, ranging from substantial understatement to intentional tax evasion. Interest accrues automatically on unpaid amounts.

The strategic advantage of voluntary disclosure is lost once SARS initiates an audit or obtains third-party information. Timing, in this context, becomes critical.

Six million crypto holders

SARS has previously indicated that approximately six million South Africans hold or trade crypto assets. It has also made clear that many of these positions have not been properly declared.  This is not a marginal compliance issue. It is systemic.

The introduction of CARF does not create a new tax. It closes information gaps. In doing so, it transforms enforcement from reactive to predictive. Tax authorities worldwide are converging around a simple premise: digital wealth should not escape the reporting obligations that bind traditional finance. South Africa is now fully embedded in that global shift.

A structural inflection point

There is a broader significance here. For more than a decade, the digital economy developed faster than regulatory capacity. Innovation outran oversight. Now it would appear that the era is ending.

SARS’ integration of crypto reporting into its international data framework marks a structural inflection point. The narrative is no longer about whether crypto is taxable. It is about whether declared positions align with the data that SARS will receive.

For compliant taxpayers, this is manageable. Proper record-keeping, clear classification analysis and alignment between declared income and transaction history will withstand scrutiny.  For those who assumed that digital equated to invisible, the margin for error has narrowed sharply.

The tax net is not expanding because the law has changed.

It is tightening because the data is now shared and made available to revenue authorities, and it would appear that from 1 March 2026, the digital shadows grow significantly shorter.

Willem J. Oberholzer is the CEO at Fyncor Group (CA(SA), M Com (Tax), Chartered Tax Advisor).

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