France’s finance committee has approved an amendment that would bring crypto‑assets into the country’s exit tax regime. The measure targets households whose crypto holdings exceed €800 000 (≈ US$896 000) and would take effect for departures on or after 1 January 2027, pending approval by the full National Assembly.
Scope of the amendment
- Eligibility – Applies to French tax residents who have lived in France for at least six of the ten years preceding their departure.
- Threshold – The €800 000 test is calculated on the total market value of the household’s crypto‑assets, whether held directly, through a service provider, or in self‑custody wallets (including foreign accounts).
- Tax base – The tax is levied on the unrealised gain: market value on the day of departure minus the total acquisition cost. An unrealised loss cannot be offset against gains in other asset classes.
- Rate – The amendment adopts the same calculation as the existing exit tax on securities: 31.4 % total (12.8 % income tax + 18.6 % social charges). The text does not specify whether social charges will apply to crypto gains.
- Reporting – Departing taxpayers must file a statement listing all crypto holdings, regardless of custody method.
Deferral and relief mechanisms
- Automatic deferral – When moving to another EU member state or to a country with a tax‑administrative assistance agreement (e.g., United Kingdom, United States, Norway), the tax is automatically deferred.
- Application‑based deferral – For moves to other jurisdictions, the taxpayer must apply for deferral before departure, appoint a French tax representative, and post a guarantee equal to 12.8 % of the gains.
- Holding‑period exemption – The liability is extinguished if the assets remain held for the required period: two years after departure, or five years if the portfolio exceeds €2.57 million (≈ US$2.88 million).
- Partial disposals – A swap of one crypto‑asset for another without cash exchange is not treated as a sale. If part of the portfolio is sold before departure, the tax is proportionally applied.
Stablecoin amendment
A companion amendment would end the current deferral for swaps into stablecoins (e‑money tokens) from 1 January 2027. Presently, crypto gains are taxed only when the holder sells for legal tender or uses the assets for purchases; swaps between crypto assets are tax‑deferred. The amendment aims to close this “legislative hole.”
Additional measures adopted by the committee
- Loss carry‑forward – Allows realised crypto losses to be carried forward for ten years.
- Self‑custody declaration – Requires holders of self‑custody wallets valued at €100 000 (≈ US$112 000) or more as of 31 December to declare them to the tax administration, with penalties up to €10 000 (≈ US$11 200) for non‑compliance.
- Rejected proposals – An ecologist amendment to include crypto‑assets in a broader personal‑wealth tax was rejected.
Fiscal context
- The amendment is part of the 2027 budget bill, which seeks roughly €54 billion (≈ US$60.5 billion) in savings and new revenue to reduce the deficit to 5 % of GDP by 2027.
- Finance committee rapporteur Philippe Juvin estimated that the combined votes could widen the 2027 deficit by about €10 billion, raising it to roughly 5.4 % of GDP.
- France’s public debt stood at 119 % of GDP at the end of June 2026, and ten‑year borrowing costs approached 5 %, the highest level since 2002.
Practical considerations for crypto holders
- Tax planning – Individuals planning to leave France should assess the timing of asset disposals, the choice of destination jurisdiction, and the possibility of converting crypto to stablecoins before the January 2027 cutoff.
- Compliance – Accurate valuation of all crypto holdings and timely filing of the required statements are essential to avoid penalties.
- Deferral strategy – Leveraging automatic deferral agreements or securing a guarantee can postpone tax payment, but the liability may be extinguished only after the prescribed holding period.
The amendment still requires a full‑chamber vote before becoming law. Stakeholders are advised to monitor the parliamentary schedule, with floor debate slated for 13 October and a vote on the revenue part set for 20 October.
Source article: www.imidaily.com
