France Proposes Stablecoin Swap Tax and Crypto Exit Tax
France's National Assembly Finance Committee has approved two significant amendments to the 2027 Finance Bill that could fundamentally change how crypto is taxed in France. From 1 January 2027, swapping into fiat-pegged stablecoins such as USDT or USDC would become a taxable event, and households with crypto holdings above 800,000 euros could face an exit tax on unrealized gains when they move abroad. Neither proposal is law yet, but both passed committee stage on the same week in October 2026, and the full Assembly was set to begin examining the Finance Bill on 13 October. If you hold crypto in France, or plan to, you need to understand what is on the table.
The Stablecoin Swap Amendment: Closing a Loophole
The amendment submitted by MP Nicolas Sansu, adopted by the Finance Committee on Wednesday, targets what its explanatory text calls a "loophole in the legislation." Under current French tax rules, a taxable disposal of crypto assets occurs when investors convert to fiat currency. A swap from Bitcoin or Ether directly into a fiat-pegged stablecoin has not, until now, been treated as a disposal for capital gains purposes. That gap would close if the Sansu amendment passes the full Assembly and becomes law.
What counts as a taxable event under the proposal
Any conversion of a crypto asset into a fiat-pegged stablecoin would constitute a taxable disposal from 1 January 2027. That means swapping BTC to USDT, ETH to USDC, or any other crypto-to-stablecoin trade would trigger a capital gains calculation at the point of exchange, not at the moment the investor eventually converts to euros or another fiat currency. Crypto-to-crypto swaps between non-stablecoin assets are not mentioned in the amendment as it currently stands.
How gains would be calculated
Gains would be calculated using the acquisition cost of the disposed asset. Where an investor holds multiple units of the same token acquired at different prices, a weighted average cost would apply. This is consistent with the approach France already uses for the existing flat tax regime on crypto disposals, so the methodology itself is not new. What changes is the trigger: stablecoin conversions join fiat conversions as disposal events.
The loss carry-forward companion amendment
A separate amendment by MP Daniel Labaronne, also adopted on the same Wednesday, would allow investors to carry forward realized crypto losses for up to ten years. This matters because, under the stablecoin swap amendment, investors could now crystallize losses as well as gains when they move into stablecoins. A ten-year carry-forward period would give holders meaningful scope to offset future gains, which partially softens the additional tax burden the Sansu amendment would create.
The Exit Tax Amendment: Unrealized Gains on Departure
A third amendment, adopted Thursday, extends France's existing exit tax mechanism to crypto assets. The proposal targets taxpayers whose household crypto holdings exceed 800,000 euros at the point they transfer their tax residence abroad. Above that threshold, unrealized gains would be subject to capital gains tax on departure, even though the investor has not sold or converted anything.
How the threshold works
The 800,000 euro figure applies at the household level, not per individual. It covers the total value of crypto holdings, not just gains. Investors below that threshold are unaffected by this specific amendment. Those above it would need to calculate unrealized gains across their entire portfolio at the point of departure. The amendment does not, as reported, specify a deferral or instalment mechanism, though France's existing exit tax rules for other asset classes do include such provisions, and the legislative process may refine the crypto version.
Who is most exposed
Long-term holders who accumulated Bitcoin or Ether at low cost bases and have large unrealized gains are the most directly affected. Anyone considering relocating from France for tax purposes before 2027 should seek specialist advice urgently, because timing relative to the law's potential enactment matters. The amendment is still subject to the full Assembly vote and subsequent legislative stages.
DAC8: The Reporting Framework Already in Force
Both amendments sit within a broader European reporting environment that is already live. The eighth amendment to the EU's Directive on Administrative Cooperation (DAC8) began applying on 1 January 2026. Under DAC8, crypto asset service providers operating in EU member states are required to collect users' identity and transaction data and report it to their national tax authority. Those national authorities then exchange the information with their counterparts across other EU member states automatically.
The first information exchanges covering 2026 transactions are due by September 2027, which means French tax authorities will receive data on French residents' crypto activity held at EU-regulated platforms well before any 2026 tax filing deadline. France, like all EU members, is implementing DAC8 in parallel with its domestic legislative agenda. The practical effect is that the French tax authority (Direction Générale des Finances Publiques, DGFiP) will have significantly improved visibility of crypto holdings and trades from 2027 onwards, making accurate self-reporting more important, not less.
Greece: A Parallel Development Worth Noting
On the same Wednesday that the French committee adopted the Sansu and Labaronne amendments, Greece's Ministry of National Economy and Finance published a separate draft bill proposing a capital gains tax on individuals' crypto profits, with an exemption for annual gains up to 500 euros (approximately 560 US dollars at the time of publication). The near-simultaneous moves in France and Greece reflect a broader trend across EU member states to tighten domestic crypto tax rules as DAC8 data begins to flow. Investors with exposure across multiple European jurisdictions should monitor both proposals as they progress through their respective national legislatures.
What This Means for French Crypto Holders
Practical steps to take now
Neither amendment is law yet. The full National Assembly was due to begin examining the 2027 Finance Bill on 13 October 2026, and further amendments, revisions, and Senate scrutiny lie ahead before anything is enacted. That said, there are concrete steps worth taking immediately.
First, review your stablecoin trading history for the current year and model what your position would look like if stablecoin swaps had been taxable. This gives you a baseline to assess future exposure if the Sansu amendment passes. Second, if you have unrealized losses across any positions, the potential ten-year carry-forward under the Labaronne amendment makes it worth understanding which losses you might want to realize before or after the proposed effective date. Third, if your household crypto holdings approach or exceed 800,000 euros and you have any plans to change your country of residence, take specialist advice before making any move.
Record-keeping under increased scrutiny
With DAC8 reporting already live and domestic tax proposals tightening, your transaction records need to be complete and traceable. Every stablecoin swap, every crypto-to-crypto trade, and every fiat withdrawal should be documented with the date, the assets involved, the value in euros at the time, and the acquisition cost of the disposed asset. Weighted average cost calculations across large portfolios with many purchases at different prices are not trivial to reconstruct after the fact. Keeping records current is far less work than reconstructing them under audit pressure.
Tax implications for the 2026 filing year
For the 2026 tax year, current rules still apply: stablecoin swaps remain non-taxable disposals in France as the law stands today. However, DGFiP will begin receiving DAC8 data on 2026 activity from September 2027. If your 2026 filing does not align with platform-reported data, queries are likely. Accuracy now matters even before the proposed new rules take effect.
Accounting and Compliance Considerations for Firms
For accounting practices and CFOs advising clients or managing treasury positions with crypto exposure, the French proposals raise several points worth addressing with clients before year-end. If the stablecoin swap amendment passes, any client currently using stablecoin conversions as a way to de-risk a crypto position without triggering a disposal will need to change their approach from 1 January 2027. Treasury policies that rely on parking value in USDT or USDC mid-position should be reviewed against the proposed effective date.
The exit tax amendment has immediate relevance for any client who holds significant crypto and is considering a cross-border restructuring or relocation. The 800,000 euro household threshold is low enough to capture many early crypto adopters who are not ultra-high-net-worth by traditional standards. Flagging this to relevant clients now, while the proposal is still in legislative draft, gives them the maximum window to take informed decisions. For a broader look at how other European jurisdictions are approaching stablecoin and crypto tax rules, see our coverage of USDT tax and USDC tax proposals in the US, which illustrates the range of approaches being considered internationally.
DAC8 compliance is not optional and is already in effect. Firms with clients who hold crypto at EU-regulated platforms should ensure those clients understand that their 2026 data will be shared automatically with DGFiP by September 2027. Germany's own evolving crypto tax landscape offers a useful comparison for firms advising clients with cross-border European exposure; see our piece on Germany's crypto tax coalition budget dispute for context on how neighbouring jurisdictions are developing their frameworks.
Frequently Asked Questions
If I swap Bitcoin to USDT today, is it taxable in France?
Under current French law, no. A crypto-to-stablecoin swap is not currently treated as a taxable disposal in France. The Sansu amendment would change this from 1 January 2027, but only if it passes the full National Assembly and completes the legislative process. Nothing has changed for the 2026 tax year.
How would the gain on a stablecoin swap be calculated?
Under the proposal, the gain would be the difference between the euro value of the stablecoin received and the acquisition cost of the crypto asset disposed of. Where you hold multiple units of the same token bought at different prices, a weighted average acquisition cost would be used, consistent with the methodology already applied to fiat conversions under current French rules.
Does the exit tax apply to my crypto if I already live abroad?
The proposed exit tax amendment applies at the point of transferring tax residence out of France. If you are already a non-resident, this amendment would not retroactively apply to you. It targets those who are currently French tax residents and move abroad after the law, if enacted, takes effect. The 800,000 euro threshold applies to the total household value of crypto holdings at departure.
What is DAC8 and does it affect me as a French crypto holder?
DAC8 is the EU's eighth amendment to the Directive on Administrative Cooperation. It requires crypto asset service providers in EU member states to report users' identities and transaction data to national tax authorities, who then share that data automatically with other EU tax authorities. It has been in force since 1 January 2026. If you hold crypto on an EU-regulated platform, DGFiP will receive data on your 2026 activity by September 2027.
Is the ten-year loss carry-forward already law?
No. The Labaronne amendment proposing a ten-year carry-forward for realized crypto losses was adopted by the Finance Committee on the same day as the Sansu stablecoin amendment. Both still need to pass the full National Assembly and complete the remaining legislative stages before becoming law. The current position is that these are committee-approved proposals, not enacted provisions.
Source: Cointelegraph