France is moving forward with a plan to tax profits from cryptocurrency-to-stablecoin trades, marking a significant shift in how digital asset transactions are treated. The National Assembly’s finance committee approved the proposal on October 7, targeting exchanges where investors receive electronic money tokens governed by the European Union’s Markets in Crypto-Assets (MiCA) regulatory framework. If passed, these new rules would come into effect on January 1, 2027.
Scope of the proposed crypto tax
The legislation specifically targets swaps of cryptocurrencies for electronic money tokens that maintain stable value against a single official currency, as defined under MiCA. This approach distinguishes such tokens from other forms of stablecoins or crypto assets, narrowing the tax’s reach to only those that directly refer to a fiat currency.
Currently, French tax law only imposes taxes when cryptocurrencies are sold for fiat currencies or used to purchase goods and services. Taxation is often deferred for exchanges between cryptocurrencies and stablecoins if they do not generate a monetary difference at the time of the swap.
The proposed amendment, introduced as I-CF1826 by Nicolas Sansu and others within the 2027 budget, would modify Article 150 VH bis of the country’s tax code. It introduces a method that calculates tax liabilities based on the gain realized, taking into account acquisition costs and fees.
Private gains on digital assets are subject to a flat tax rate of 31.4%, combining 12.8% income tax with an 18.6% social security contribution. Qualified investors may opt for the progressive income tax scale instead of the flat rate.
Calculation method and transition rules
The amendment would require the sale value to be calculated by subtracting eligible expenses from the consideration received in the swap. For assets acquired at various prices, an average cost method would be used to determine the taxable gain. Importantly, the tax would apply only to the actual profit realized from the exchange, not the total transaction value.
A transition rule would allow taxpayers to use the recorded purchase cost or allocate the total portfolio cost across assets held as of December 31, 2026, for transactions made after the law’s effective date. The amendment would become applicable to qualifying transactions starting January 1, 2027.
| Current Tax Trigger | Proposed Change (2027) |
|---|---|
| Crypto to fiat sales, goods/services purchases | Crypto to stablecoin swaps (defined by MiCA) |
Mini dictionary: MiCA, or Markets in Crypto-Assets, is a European Union regulation designed to create a harmonized legal framework for crypto asset issuance and service provision throughout EU countries. It introduces specific rules for stablecoins, electronic money tokens, and crypto asset service providers.
Exit tax and loss treatment updates
In addition to the core crypto tax reform, the finance committee supported a separate amendment to extend the exit tax to cryptocurrency holders moving out of France. The extension would apply to individuals who have resided in France for at least six of the past ten years and who hold crypto portfolios valued above €800,000. The planned implementation date is also January 1, 2027.
Another amendment allows for offsetting crypto-related losses against gains in digital assets over the next ten years, treating them similarly to securities. Under the current regime, such offsets generally apply only within the same tax year.
The new approach would tax token swaps in the same way as sales to fiat currency, addressing what policymakers view as a loophole for deferring gains during conversions between crypto and stablecoins.
Legislative outlook
Although the finance committee has approved the amendments, they must still be passed by Parliament to become law. The measures would take effect at the start of 2027 if adopted, giving investors and institutions time to prepare for the changes. The reforms are part of a broader effort to harmonize digital asset taxation and align local policies with evolving European standards under MiCA.
