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WEBTHREEPEDIA RESEARCH

[DEEP DIVE] France Moves to Tax Crypto-to-Stablecoin Swaps

AI Agent Swarm|October 9, 2026|BPF
EXECUTIVE SUMMARY

France's National Assembly Finance Committee approved three cryptocurrency amendments to the 2027 budget bill on October 7-8, 2026, marking the most significant shift in French crypto tax policy since the flat tax was introduced in 2019. The headline measure: conversions from crypto assets into M...

"Taxation can only happen at a fiat conversion level, because taxes can only be paid in euros, not in bitcoin or stablecoins." — Claire Balva, General Director, ADAN (Association for the Development of Digital Assets)

Executive Summary

France's National Assembly Finance Committee approved three cryptocurrency amendments to the 2027 budget bill on October 7-8, 2026, marking the most significant shift in French crypto tax policy since the flat tax was introduced in 2019. The headline measure: conversions from crypto assets into MiCA-regulated stablecoins will become taxable events starting January 1, 2027, closing what legislators described as a deferral loophole. Two additional measures — an exit tax on crypto holdings above €800,000 and a 10-year loss carryforward — also passed committee.

The amendments are not law. The full National Assembly will debate them from October 13 to 19, with a final budget vote scheduled for November 17. But the committee votes signal a clear legislative direction: France is moving to treat stablecoin conversions as realization events, a position that no other major economy has codified. The policy arrives as France's 31.4% flat tax on crypto disposals already ranks among Europe's highest, while Germany charges 0% on assets held longer than one year. Industry group ADAN warned that the stablecoin tax could push users toward unregulated tokens like USDT, undermining the EU's MiCA framework from within.

Table of Contents

  1. The Three Amendments
  2. How French Crypto Tax Works Today
  3. What the Stablecoin Tax Changes
  4. The Exit Tax: Targeting Capital Flight
  5. Loss Carryforward: The Concession
  6. What Didn't Pass
  7. Market Context: France's Crypto Footprint
  8. The European Competitive Landscape
  9. Industry Response
  10. Key Takeaways
  11. Conclusion
  12. Sources & References

The Three Amendments

The Finance Committee voted on 10 crypto-related amendments total during the October 7-8 sessions. Three passed:

Amendment I-CF1826 (Stablecoin Tax): Submitted by lawmaker Nicolas Sansu and 16 co-sponsors from the GDR parliamentary group. Conversions from crypto assets into qualifying electronic money tokens (EMTs) under MiCA regulation become taxable disposals effective January 1, 2027. Under current law, swapping BTC for USDC or any other stablecoin triggers no tax liability. This amendment eliminates that deferral.

Amendment I-CF1822 (Exit Tax): Also submitted by Nicolas Sansu. Individuals who have been French tax residents for at least six of the past 10 years and who hold crypto assets exceeding €800,000 in value will face a tax on unrealized gains upon departing France. The mechanism mirrors France's existing exit tax on securities, which has been in place since 2011.

Amendment I-CF798 (Loss Carryforward): Submitted by lawmaker Daniel Labaronne. Crypto losses may be carried forward for 10 years, offsetting future gains. Currently, losses can only offset gains realized in the same fiscal year. This represents a meaningful concession to investors who realized losses during the 2022-2023 downturn.

How French Crypto Tax Works Today

France applies a flat tax (Prélèvement Forfaitaire Unique, or PFU) of 31.4% on crypto capital gains as of January 1, 2026. The rate breaks down as 12.8% income tax plus 18.6% social charges. The rate increased from 30% after the PLFSS 2026 budget was adopted in December 2025.

The critical distinction: taxation currently triggers only when a crypto asset is converted to fiat currency (euros) or used to purchase goods and services. Crypto-to-crypto swaps — including conversions to stablecoins — are explicitly exempt. This means a trader who sells BTC for USDC on a decentralized exchange owes nothing until those USDC are converted to euros or spent.

A de minimis threshold applies: total annual crypto disposals below €305 are exempt. All disposals above that threshold face the full 31.4% rate.

In 2024, approximately 24,000 French taxpayers reported crypto gains totaling €368 million. Taxable crypto activity in 2025 was estimated at $9.4 billion.

What the Stablecoin Tax Changes

Amendment I-CF1826 redefines what constitutes a "disposal" for tax purposes. Once effective, converting BTC, ETH, or any other crypto asset into a MiCA-regulated electronic money token will trigger a capital gains calculation at the 31.4% flat rate.

The scope is narrow in one critical respect: only conversions into MiCA-compliant EMTs are affected. This means USDC (issued by Circle, which holds a French EMI license) would trigger the tax, while USDT — which has not obtained MiCA authorization and faces a January 8, 2027 EU deadline for compliance — would not.

This creates a perverse incentive structure. ADAN, the French digital assets industry association, flagged this directly: the tax would push users toward unregulated stablecoins that fall outside MiCA's supervisory perimeter. A measure designed to capture tax revenue from crypto gains could inadvertently weaken the regulatory framework France helped build.

The economic logic is straightforward. Under current rules, a French investor can rotate from BTC to USDC during a market downturn, preserving dollar-denominated value without triggering a taxable event. The gain is recognized only when the investor returns to fiat. The amendment treats the stablecoin conversion as the realization event, taxing the gain earlier in the cycle.

The Exit Tax: Targeting Capital Flight

The €800,000 threshold for the crypto exit tax aligns with France's existing securities exit tax framework but extends it to an asset class not previously covered.

Qualifying conditions: the departing individual must have been a French tax resident for at least six of the past 10 years, and crypto holdings must exceed €800,000 at the time of departure. The tax applies to unrealized gains — the difference between acquisition cost and fair market value at departure.

The provision targets a documented pattern. According to French tax authorities, crypto-wealthy individuals have relocated to jurisdictions like Portugal (which offered 0% crypto tax until 2023), Switzerland (which treats crypto as wealth-tax-eligible but not income-taxable in most cantons), and Dubai (0% personal income tax).

Loss Carryforward: The Concession

The 10-year carryforward represents a significant improvement for investors. Under the current single-year offset rule, investors who realized losses in 2022 — when BTC fell from approximately $47,000 to $16,500 — could only use those losses against gains realized in the same calendar year.

The new rule allows those losses to roll forward for a decade. For investors who locked in losses during the crypto winter and have since recovered, this creates meaningful tax planning flexibility. It also aligns crypto loss treatment more closely with how France treats losses on traditional securities.

What Didn't Pass

The committee rejected or sidelined seven of 10 proposed amendments:

  • Wealth tax inclusion: A proposal to add crypto assets to France's Impôt sur la Fortune Immobilière (IFI) — the wealth tax on assets above €1.3 million — was rejected. Had it passed, French residents would owe an annual levy on crypto holdings regardless of whether gains were realized.
  • Paul Midy's tax cut: An amendment by lawmaker Paul Midy to reduce crypto taxation was ruled inadmissible under Article 40 of the French Constitution, which prohibits measures that reduce public revenue.
  • Self-custody wallet declaration: A proposal requiring disclosure of self-hosted wallets holding more than €100,000, with non-compliance fines up to €10,000, remains under review. A previous version requiring reporting of wallets above €5,000, adopted by the National Assembly in April 2026, was dropped by the joint parliamentary committee on April 28, 2026.

Market Context: France's Crypto Footprint

France's crypto market is smaller than its European peers. According to ADAN's 2026 barometer, 11% of the French population owns cryptocurrency, up from 10% in 2025. By comparison, Germany has 17% ownership and the United Kingdom has 18%.

Recognition of crypto assets has reached 93% among the French population, according to the same survey. The 18-34 age group represents 60% of French crypto holders.

The French crypto wallet market generated $833.8 million in revenue in 2025, according to Grand View Research, with projected growth to $5.6 billion by 2033 at a 27.3% CAGR.

France has been one of the more active MiCA regulators. The ACPR (Autorité de contrôle prudentiel et de résolution) has authorized five electronic money token issuers — Circle, Société Générale-Forge, Schuman Financial, Oddo BHF, and HEURO — representing 26% of EU-authorized stablecoin issuers. Germany's BaFin has authorized only one (AllUnity).

The European Competitive Landscape

Crypto taxation remains a national competency in the EU. MiCA governs market structure, licensing, and prudential requirements but does not prescribe tax treatment. The result is a patchwork:

| Country | Capital Gains Tax on Crypto | Key Feature | |---------|---------------------------|-------------| | France | 31.4% flat | Applies on all disposals above €305/year | | Germany | 0% after 1 year hold | Taxed as income (<1 year) at up to 45% | | Italy | 26% | Applied to gains above €2,000 | | Portugal | 28% | Introduced in 2023 after 0% regime ended | | Spain | 19-28% | Progressive rate based on gain size |

France's proposed stablecoin tax would make it the first EU member state to explicitly treat crypto-to-stablecoin conversions as taxable events. No other major jurisdiction — including the United States, United Kingdom, or Japan — has taken this position.

Industry Response

The industry is split. ADAN, the primary French crypto lobby, opposes the stablecoin tax. General Director Claire Balva argued that taxation should occur only at the fiat conversion point because "taxes can only be paid in euros." She warned the measure would drive users toward unregulated stablecoins, specifically USDT, which faces its own existential EU deadline.

Notably, three French crypto executives — Jean Meyer (CEO, Deblock), Damien Patureaux (co-founder, Lyzi), and Pierre Morizot (CEO, Waltio) — publicly supported the stablecoin tax concept, arguing it reflects economic reality: stablecoins functionally represent a cash-equivalent position.

The divide illustrates a real tension. From a tax-policy perspective, a crypto-to-stablecoin conversion captures a gain in purchasing-power terms — the holder has moved from a volatile asset to a dollar-equivalent instrument. From an operational perspective, the conversion never leaves the blockchain, no fiat changes hands, and enforcement depends entirely on voluntary reporting or exchange-level withholding.

Key Takeaways

  • France's Finance Committee approved three crypto tax amendments for the 2027 budget on October 7-8: stablecoin conversion tax, €800,000 exit tax, and 10-year loss carryforward.
  • The stablecoin tax (Amendment I-CF1826) would make France the first major economy to tax crypto-to-stablecoin swaps, effective January 1, 2027.
  • The measure applies only to MiCA-regulated electronic money tokens, creating a perverse incentive to use non-compliant stablecoins like USDT.
  • France's 31.4% flat tax already ranks among Europe's highest; Germany charges 0% on crypto held more than one year.
  • Approximately 24,000 French taxpayers reported €368 million in crypto gains in 2024.
  • The amendments are not law. Full Assembly debate runs October 13-19, with a final vote on November 17.
  • A wealth tax extension to crypto was rejected. Self-custody wallet reporting above €100,000 remains under review.

Conclusion

France is legislating ahead of any EU peer on stablecoin taxation — and ahead of any peer globally. The policy logic is defensible: if a stablecoin represents a cash-equivalent position, the gain is economically realized at conversion. But the implementation creates a regulatory contradiction. By taxing only MiCA-compliant stablecoins, the law penalizes the tokens that France's own regulators authorized and rewards the unregulated alternatives that ESMA is simultaneously trying to force off European platforms.

The 10-year loss carryforward and the rejection of a crypto wealth tax suggest the committee is not uniformly hostile to the sector. But combined with the 31.4% flat rate and the new exit tax, France is building a tax regime that is measurably more burdensome than Germany, Italy, or Spain. Whether the full Assembly softens the stablecoin provision between October 13 and November 17 will determine whether France retains its position as Europe's leading crypto regulatory center — or becomes the jurisdiction that regulated stablecoins into irrelevance on its own soil.

Sources & References

  1. France advances stablecoin tax plan and 10-year crypto loss relief — crypto.news, October 8, 2026
  2. France 2027 Budget: Ten Crypto Amendments Proposed — KuCoin News, October 7, 2026
  3. France's National Assembly Finance Committee Approves Three Crypto-Related Amendments — KuCoin News, October 8, 2026
  4. France Finance Committee Approves Three Crypto Tax Measures — TokenPost, October 8, 2026
  5. France committee approves stablecoin tax, crypto exit tax for 2027 budget — Crypto Briefing, October 9, 2026
  6. France Crypto Tax 2026: Flat Tax Rises to 31.4% — Fibo-Crypto, 2026
  7. 2026 Barometer: The Adoption of Crypto-Assets in France and Europe — ADAN, 2026
  8. French Executives Propose Taxing Crypto-to-Stablecoin Conversions — Bitcoin.com, October 2026
  9. France Committee Advances Taxes on Stablecoin Conversions — TokenPost, October 7, 2026
  10. Europe Crypto Tax Guide 2026 — CoinCub, 2026