
French lawmakers are considering whether certain crypto gains should become taxable before an investor converts assets into euros. Their discussion centres on two decisions: moving into regulated digital cash and moving tax residence abroad with a large portfolio.
Key Takeaways
- Swaps into some regulated fiat-linked tokens could become taxable from 2027.
- Large crypto portfolios could enter France’s exit-tax system when a holder leaves.
- Another measure would give crypto losses a 10-year carry-forward period.
- None of the proposals has changed the current rules.
Two decisions are at the centre of the debate
The Finance Committee reviewed several crypto-tax amendments during its work on France’s 2027 budget. Together, they ask when a gain becomes sufficiently real to tax—even when the investor has not sent euros to a bank account.
Proposed trigger one
Crypto → regulated e-money token
A gain could be calculated when a holder swaps into an eligible fiat-linked token.
Proposed trigger two
France → another tax residence
Large unrealised gains could be assessed when a taxpayer leaves the country.
Those are different events. One concerns a transaction inside a portfolio; the other concerns the point at which France may lose the right to tax a future sale.
A regulated stablecoin swap could count as a taxable exchange
Amendment I-CF1826 would change the treatment of exchanges into electronic-money tokens, known as EMTs, from January 1, 2027. MiCA defines an EMT as a crypto asset designed to maintain its value by referencing one official currency.
That wording is narrower than the catch-all term “stablecoin.” The draft refers specifically to MiCA electronic-money tokens, which generally covers regulated euro- or dollar-linked tokens. A token marketed as stable would not automatically fall under the rule.
Example: A Bitcoin holder who swaps BTC for an eligible dollar-linked token could need to calculate the gain on that trade, even though no cash has entered a bank account.
The amendment’s explanatory note argues that a swap into a fiat-pegged token currently allows a gain to remain untaxed longer than a direct conversion into fiat currency. Its proposed change would move that tax point forward.
Long-term holders would also face a record-keeping decision. The text allows them to document the historic cost of each asset or choose a one-time, irreversible method for allocating the portfolio’s acquisition cost. That choice would affect the taxable gain on a later eligible swap.
Leaving France could bring paper gains into scope
The second measure addresses a different route. Amendment I-CF1822 would include crypto assets in France’s exit-tax framework when a taxpayer changes residence.
It would apply to people who have been French tax residents for at least six of the previous 10 years and whose household crypto portfolio exceeds €800,000 at departure. The draft includes assets held directly, through a crypto-asset service provider or through another third party, placing self-custodied wallets inside the proposed calculation.
How an exit tax differs from a sale
The calculation would use unrealised gains at the time a person leaves France. The amendment adapts the existing exit-tax framework, including deferral and relief mechanisms, rather than treating every departure as an immediate sale of crypto.
The purpose is clear: a large gain should not automatically fall outside French tax jurisdiction simply because the holder moves before selling. Whether that approach survives the parliamentary process remains a separate question.
The proposals also offer a longer life for losses
The package does not focus only on earlier gain recognition. Amendment I-CF798 would allow losses on crypto disposals to be carried forward for 10 years.
That could help investors whose gains and losses fall in different tax years. Someone who paid tax after a profitable year, then realised losses during a later market decline, would have more time to use those losses against future taxable gains.
The three measures therefore serve separate functions: one changes a specific type of swap, another concerns a departure from France, and the third changes the treatment of losses after disposal.
The committee vote has not changed the rules
France has not introduced a new stablecoin tax or a crypto exit tax. On October 9, the Finance Committee rejected the revenue section of the 2027 budget as a whole, after reviewing and voting on individual amendments.
LCP, the National Assembly’s parliamentary channel, reported that the section failed by 31 votes to three, with two abstentions. When the full Assembly begins its debate on October 13, it will return to the government’s original budget text.
The crypto measures can be tabled again, rewritten or dropped. For holders, the immediate rules remain the same; the larger change is that lawmakers are now openly debating whether moving into regulated digital money or moving abroad should carry tax consequences similar to cashing out.
This article is for informational purposes only and does not constitute tax or legal advice. Taxpayers should seek advice from a qualified professional regarding their individual circumstances.



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