France's proposed crypto tax overhaul would treat swaps from Bitcoin or Ether into certain stablecoins as taxable disposals, requiring investors to report gains immediately rather than deferring taxation until they withdraw cash.
The National Assembly's Finance Committee adopted amendment I-CF1826 on October 7, which adds this provision to a broader revision of how private crypto gains are calculated. If enacted, the rule would apply to disposals and exchanges beginning January 1, 2027.
Current Tax Treatment vs. Proposed Changes
Under existing French tax authority guidance, crypto-to-crypto exchanges receive tax deferral. Only conversions to fiat currency or use of crypto to purchase goods and services trigger immediate taxation under the private-disposal regime.
The amendment would eliminate this deferral specifically for exchanges into e-money tokens, as defined by the EU's Markets in Crypto-Assets regulation (MiCA). MiCA defines such tokens as crypto-assets designed to maintain stable value by reference to an official currency. USDC, issued by Circle, qualifies under this definition.
For an investor reducing market exposure by swapping Bitcoin into USDC, the practical effect would be earlier recognition of any gain. The proceeds would remain in a crypto wallet or exchange account, but the tax obligation would arise at the moment of the swap.
Basis Calculation and Transition Options
The proposal also changes how acquisition costs are calculated. Currently, France uses a portfolio-based allocation method that distributes the total acquisition price across each taxable disposal.
The amendment would replace this with a weighted-average approach focused on the specific assets being disposed. For holdings acquired before 2027, investors would have two options:
- Use actual documented acquisition costs under the new basis rules
- Allocate the portfolio acquisition price calculated under current rules as of December 31, 2026, distributed proportionally by the value of assets held on that date
This second allocation option preserves a pool of historical acquisition cost. Once an investor files a tax return reporting a taxable disposal after January 1, 2027, their chosen method becomes irrevocable for the entire portfolio.
Implications and Loss Restrictions
The amendment distinguishes between deferred and taxable exchanges. Taxable exchanges reset the basis of received assets to their consideration value, preventing double taxation if proceeds later reach a bank account at the same value.
Existing crypto loss restrictions would remain unchanged. Under French tax rules, crypto gains and losses offset within the same tax year, but net losses cannot be carried forward to future years or offset gains on other assets. This timing mismatch can affect outcomes when losses and gains occur in different years.
The amendment does not alter reporting requirements for asset-specific basis or weighted-average calculations, meaning investors would need to maintain detailed acquisition evidence and track basis through each swap.
The National Assembly held plenary discussion of the measure on October 13, continuing the legislative process toward potential enactment.
