France's Stablecoin Tax, Exit Tax, and Self-Custody Wallet Rules: What's Changing
French lawmakers have taken a significant step toward taxing crypto-to-stablecoin swaps, and two further proposals targeting high-net-worth holders and self-custody wallet owners are moving through the 2027 Finance Bill process. If you hold USDT, USDC, or any stablecoin as part of your crypto portfolio in France, the next few weeks in the National Assembly matter a lot to your tax position.
What the National Assembly Actually Voted On
On Friday 17 October 2026, France's National Assembly passed Amendment I-3898 by the narrowest of margins: 38 votes in favour, 37 against, and 25 abstentions. The measure was first introduced in committee by MP Nicolas Sansu and approved at committee stage on 7 October 2026. The full Assembly is scheduled to vote on the first part of the 2027 Finance Bill on the following Tuesday, though it remains unclear which of the pending crypto-related proposals will be debated or put to a vote at that sitting.
The stablecoin swap taxable event
Under current French tax law, converting a cryptocurrency into a stablecoin is generally treated as a like-for-like exchange and does not trigger an immediate tax liability. Amendment I-3898 would change that. If enacted for the 2027 tax year, moving Bitcoin, Ether, or any other crypto asset into USDT, USDC, or another stablecoin would count as a disposal and crystallise any unrealised gain at that point.
The gain would be calculated using the acquisition cost of the crypto sold and a weighted average purchasing price method. In practical terms, that means you can no longer park gains in stablecoins tax-free as a temporary defensive move; the act of converting becomes the taxable moment, regardless of whether you ever touch fiat euros.
The loss carry-forward proposal that failed
In the same session, the Assembly rejected a separate proposal that would have allowed investors to carry realised crypto losses forward for up to ten years. The vote was decisive: 18 in favour, 75 against, 3 abstentions. For anyone sitting on losses from the 2022 or 2023 bear markets who had hoped to offset future gains over a longer window, that door has closed for now.
Two More Proposals Still on the Table
Beyond the stablecoin swap amendment, two additional measures are under active consideration as part of the broader 2027 budget debate. Neither has been voted on yet, and each carries its own implications depending on the size and structure of your portfolio.
Exit tax on unrealised crypto gains
One amendment would extend France's existing exit tax regime to cryptocurrency holdings. Under this proposal, any taxpayer whose aggregate crypto portfolio exceeds €800,000 (approximately $895,000) and who transfers their tax residency abroad would face a tax charge on unrealised gains at the point of departure, not at the point of sale.
France already applies exit tax rules to certain financial assets when residents relocate. Bringing crypto into scope would close what legislators apparently view as a loophole used by high-value holders to relocate before liquidating positions. If the amendment passes, the timing of an international move becomes a formal tax planning variable for any French crypto investor above the threshold.
Self-custodial wallet disclosure above €100,000
A further proposal would require individuals to declare the contents of self-custodial wallets whenever their total value exceeded €100,000 (approximately $112,000) in the relevant tax year. This sits alongside earlier reporting debates that drew significant pushback from the crypto community. France has already moved to require disclosure of certain exchange-held wallet balances above similar thresholds, so extending the obligation to hardware wallets and software wallets held outside exchanges would represent a substantial broadening of the reporting net.
The practical challenge is verification: self-custodial wallets are, by definition, outside the custody of any regulated entity. The proposal places the compliance burden squarely on the individual taxpayer, who would need to value and declare holdings they control directly.
What This Means for Your Crypto Tax in France
France currently taxes crypto capital gains under a flat rate regime. The stablecoin amendment does not change the rate itself; it changes the trigger. Right now, many French holders treat stablecoin positions as a holding pattern between trades. If Amendment I-3898 becomes law, that strategy disappears entirely, and every rotation into USDT or USDC becomes a reportable, taxable event that needs to be tracked with the correct cost basis.
Record-keeping becomes critical
The weighted average purchasing price method required by the amendment means you need an accurate running record of what you paid for every crypto asset in your portfolio, across every acquisition. If you've been buying Bitcoin or Ether in irregular amounts over time, your average cost basis changes with every purchase. Without precise records, calculating the correct gain on a stablecoin swap will be impossible, and the tax authority will not accept estimates.
Start documenting your acquisition prices, dates, and quantities now, well before any 2027 legislation takes effect. Understanding how France's 31.4% flat rate interacts with the stablecoin tax proposal gives important context for how large that tax hit could be on a successful position.
Timing decisions around the exit tax threshold
If your total crypto portfolio is approaching or above €800,000 and you have any plans to relocate outside France, the exit tax proposal transforms what might have been a lifestyle decision into a live tax risk. A departure after the law passes could trigger a charge on gains you haven't yet realised. Legal advice on the timing of any move, relative to the bill's passage date, is worth obtaining sooner rather than later.
Self-custody holders: assess your exposure
If you hold crypto on a hardware wallet or non-custodial software wallet and your holdings have at any point in the year exceeded €100,000, the proposed declaration requirement would apply to you specifically. This is separate from exchange reporting obligations. Review what you hold, at what value, and keep records of wallet addresses and balances with dated valuations. For more on how France has approached wallet reporting in the lead-up to these debates, see our earlier coverage of France's proposed crypto wallet disclosure requirements.
Timeline and What Comes Next
The National Assembly's vote on the first part of the 2027 Finance Bill was scheduled for the Tuesday following the 17 October session. Amendment I-3898 has cleared the Assembly but the Finance Bill must complete its full legislative journey, including review in the Senate, before becoming law. The stablecoin swap change, if confirmed, would apply from the 2027 tax year. The exit tax and self-custody reporting proposals have not yet been voted on and their fate depends on the bill's remaining legislative stages.
Watch the Assembly's official schedule and the Senate Finance Committee's proceedings. Any of these amendments could be modified, combined, or dropped before the bill is finalised. What is clear is that the direction of travel in France is toward broader crypto taxation, tighter reporting, and fewer opportunities to defer a tax liability by moving between asset classes within the crypto ecosystem.
For the broader context of how these French proposals fit into the global picture of crypto tax tightening, our overview of France's stablecoin swap and exit tax proposals covers the earlier stages of this legislative process.
Source: Cointelegraph
Frequently Asked Questions
Is swapping crypto to USDT or USDC currently taxable in France?
Under current rules, converting one crypto asset to a stablecoin is generally treated as a like-for-like exchange and does not trigger an immediate tax liability. Amendment I-3898, if enacted, would change that from 2027, making such swaps taxable disposals at the point of conversion.
What rate would apply to gains on stablecoin swaps?
The amendment changes when tax is triggered, not the rate. France currently applies a flat rate on crypto capital gains. The gain on a stablecoin swap would be calculated using your acquisition cost and the weighted average purchasing price of the asset sold.
Who is affected by the proposed exit tax on crypto?
The proposal targets taxpayers whose total crypto portfolio exceeds €800,000 and who transfer their tax residency outside France. If passed, unrealised gains would be taxed at the point of departure, not at the point of eventual sale.
Do I have to declare crypto held in a hardware wallet in France?
Not yet under current law. The pending amendment would require declaration of self-custodial wallet holdings whenever their total value exceeded €100,000 in the relevant tax year. This has not been voted on and is still under consideration as part of the 2027 Finance Bill.
Can I carry forward crypto losses in France to offset future gains?
A proposal to allow a ten-year loss carry-forward was rejected by the National Assembly in the same session, with 75 votes against. Under the rules as they currently stand, there is no long-term carry-forward mechanism for realised crypto losses.