At 19:11 UTC on October 7, 2026, the French National Assembly’s Finance Committee adopted amendment I-CF1826 to the 2027 Finance Bill. The measure would make some crypto-to-stablecoin conversions taxable from January 1, 2027. At 07:55 UTC the next day, the committee adopted amendment I-CF1822, which would apply an exit tax to unrealized gains in crypto portfolios worth more than €800,000.
Both amendments were introduced by Nicolas Sansu and other lawmakers from the Democratic and Republican Left group. Committee adoption moves the provisions into the bill’s first reading. It does not make either amendment law.
Stablecoin conversions would lose their deferral
Amendment I-CF1826 changes Article 150 VH bis of France’s General Tax Code. That article currently permits qualifying crypto-for-crypto exchanges without an immediate tax calculation. The amendment removes that treatment when the seller receives an electronic money token as defined by Article 3(1)(7) of the EU’s Markets in Crypto-Assets Regulation.
The scope is narrower than every asset commonly called a stablecoin. It follows MiCA’s legal category for electronic money tokens. A token must fall within that definition for the new exception to apply. The amendment does not name individual tokens.
A holder who converts another crypto asset into a qualifying electronic money token would calculate a gain or loss at the conversion. The text defines gross gain or loss as the difference between the disposal price and the acquisition price of the crypto assets or related rights that were sold. It allows documented disposal costs to reduce the disposal price and documented acquisition costs to increase the acquisition price.
The proposal also replaces portfolio-wide cost allocation with weighted-average acquisition cost for crypto assets of the same type. Assets received in a deferred crypto-for-crypto exchange inherit the acquisition price of the assets surrendered. Assets received in a taxable exchange take the value used to calculate that exchange’s gain or loss, adjusted for any cash payment made or received.
This cost-basis rewrite changes the records a holder would need. Instead of calculating each disposal against one aggregate portfolio formula, the taxpayer would track acquisition prices by asset type. The rule for deferred exchanges preserves the surrendered asset’s basis, while the rule for taxable exchanges starts the received asset at the value already used for the gain or loss calculation. Documented transaction costs affect those figures.
Holdings acquired before January 1, 2027 get a transition rule. A taxpayer could use the actual documented acquisition cost of each asset. The alternative is to allocate the portfolio’s total acquisition cost as of December 31, 2026 across the assets held on that date in proportion to their values. That choice becomes irrevocable for the entire portfolio when the taxpayer files the first return reporting a taxable disposal after January 1, 2027.
For DeFi users in France, the practical change is the timing of tax. Moving from a volatile crypto asset into a qualifying fiat-referenced token would no longer preserve the existing deferral. Swaps used to park collateral, reduce exposure, repay a position, or move funds between protocols could create a tax event even when no euros enter a bank account. The amendment itself does not provide protocol-specific exceptions.
Exit tax would reach large crypto portfolios
Amendment I-CF1822 creates Article 167 ter of the General Tax Code. It covers taxpayers who were resident in France for at least six of the ten years before moving their tax residence abroad. The taxable base is the unrealized gain on crypto assets and related rights held on the move date when their combined value exceeds €800,000. The provision applies to assets held directly, through a crypto-asset service provider, or through another third party.
The text calculates that unrealized gain as the difference between the portfolio’s value on the transfer date and its total acquisition price under Article 150 VH bis. A decree would set the valuation method. When no reference price exists, the amendment calls for fair market value. An unrealized loss could not offset unrealized gains covered by the existing Article 167 bis exit tax and could not be carried forward.
Payment deferral, relief, reporting, control, and collection rules from the existing exit-tax regime would also apply, subject to crypto-specific changes. Crypto-for-crypto exchanges without a cash adjustment would not count as a disposal. A taxable sale before the applicable holding period ends would make tax payable in proportion to the part of the portfolio sold.
That proportional rule works at portfolio level. The fraction due would be the sale price divided by the portfolio’s value when the taxpayer moved. It avoids treating every later asset sale as a disposal of the whole portfolio, while preserving a tax claim against the part sold before the applicable holding period ends. The amendment leaves the existing deferral and relief framework in place instead of creating a separate payment schedule for crypto.
The reporting rule reaches assets held through a crypto-asset service provider or another third party, as well as assets held directly. Taxpayers would have to list crypto kept on foreign accounts or wallets and crypto held in self-custody. The amendment would apply to changes of tax residence from January 1, 2027.
The two committee votes leave the final text open. The bill can change during the remaining National Assembly and parliamentary process, so French users and operators do not yet have an enacted rule to implement. The unresolved points include whether both amendments survive, how the valuation decree treats assets without a reference price, and which tokens fall inside the MiCA electronic money token definition in practice.
