At 07:55 UTC on October 8, 2026, the French National Assembly’s Finance Committee adopted amendment I-CF1822, a proposal to extend France’s exit tax to crypto portfolios worth more than €800,000. The committee had adopted amendment I-CF1826 at 19:11 UTC the previous day, targeting gains realized when a taxpayer swaps cryptoassets for certain fiat-referenced stablecoins.
Both measures sit inside the first reading of France’s 2027 finance bill. The Assembly records classify each amendment as adopted by the Finance Committee. Committee approval does not make either measure law.
Stablecoin swaps would become taxable disposals
Amendment I-CF1826 changes article 150 VH bis of the French tax code. Its central provision removes the tax deferral for an exchange in which the seller receives an electronic money token as defined by Article 3(1)(7) of the EU’s Markets in Crypto-Assets Regulation. That category covers stablecoins tied to one official currency under MiCA.
France currently defers tax on many crypto-to-crypto exchanges. The amendment would carve qualifying electronic money tokens out of that treatment. A holder exchanging another cryptoasset for such a stablecoin would calculate a gain or loss at the time of the exchange.
The proposed calculation starts with the actual sale price or the value of the consideration received. It allows documented disposal costs to reduce that amount. The acquisition price is the amount paid in legal tender, or the value used for gift-tax purposes when the asset was received without payment. Documented acquisition costs can increase the basis.
The amendment also changes basis accounting. For cryptoassets of the same type acquired at different prices, it specifies a weighted average acquisition value. Assets received in a deferred crypto-to-crypto exchange inherit the acquisition price of the assets surrendered. Electronic money tokens received in a taxable exchange instead take the consideration value used to calculate the gain or loss, adjusted for any cash balance paid or received.
The new rules would apply to disposals and exchanges from January 1, 2027. Taxpayers holding crypto before that date would get two basis options. They could substantiate the actual acquisition cost of each asset. Alternatively, they could allocate the portfolio’s total acquisition price as of December 31, 2026 across the assets held on that date in proportion to their value. The second choice would become irrevocable when the first return reporting a taxable disposal after January 1, 2027 is filed.
For active DeFi users, the practical change is the timing of tax. Moving gains into a qualifying stablecoin would create a reporting event instead of preserving deferral until a later conversion or purchase. Users would also need records that distinguish electronic money tokens from other cryptoassets and support each asset’s basis.
The transition method matters for portfolios built through many trades. The actual-cost option requires evidence for each asset or right. The allocation option starts with the portfolio’s total acquisition price at December 31, 2026 and spreads it according to the assets’ values that day. Because that election becomes irrevocable on the first applicable return, a taxpayer could not switch methods later for a more favorable result. Neither option removes the need to document disposal costs, acquisition costs and any cash adjustment exchanged with the assets.
Exit tax would reach larger crypto portfolios
Amendment I-CF1822 creates a proposed article 167 ter. It applies when a tax household has been resident in France for at least six of the previous ten years and transfers its tax residence outside France. The household’s cryptoassets must have a combined value above €800,000 on the transfer date.
The scope includes crypto held directly, through a cryptoasset service provider, or through another third party. The latent gain equals the portfolio’s value on the transfer date minus its total acquisition price under article 150 VH bis. A latent loss could not offset latent gains covered by the existing exit-tax provision and could not be carried forward.
A decree would set the valuation method. If an asset has no reference price, the amendment says its market value would apply. The existing exit-tax rules for payment deferral, relief or refunds, declarations, control and collection would also govern crypto gains, subject to specific adaptations.
One adaptation keeps crypto-to-crypto exchanges without a cash adjustment from being treated as disposals for exit-tax purposes. Another calculates tax due after an early sale in proportion to the fraction of the original portfolio sold. The fraction is the sale price divided by the portfolio value on the date the taxpayer left France.
The disclosure requirement reaches beyond custodial accounts. A departing taxpayer would attach a statement of cryptoassets held on the transfer date, including assets in foreign accounts or wallets and assets held in self-custody. The proposal would cover transfers of tax residence from January 1, 2027. Implementing details would require a decree from the Council of State.
For holders near the €800,000 threshold, valuation and recordkeeping would determine whether the rule applies. Self-custody would not remove assets from the calculation. Protocol operators and tax tooling providers would need to preserve enough transaction history to reconstruct portfolio basis and the transfer-date value.
The amendment treats the portfolio as one pool when part of it is sold before the relevant holding period expires. Tax becomes payable in the same proportion as the sale price bears to the portfolio value recorded at departure. That design makes the departure-date valuation important after the taxpayer moves, even if the later sale involves only some assets. The declaration would also have to identify holdings outside France and assets in wallets controlled by the taxpayer.
The unresolved issue is whether either committee amendment survives the remaining legislative process and appears in the enacted 2027 finance law. Until then, stablecoin swaps retain their current treatment and the proposed crypto exit tax has no legal effect.
