France Weighs 31.4% Tax on Crypto-to-Stablecoin Swaps

A swap from bitcoin into a MiCA-regulated stablecoin would become a taxable event in France under an amendment to the country's 2027 budget. The National Assembly's finance committee adopted the text on 7 October, and it would apply to disposals and exchanges carried out from 1 January 2027.

The amendment does not invent a new tax. It removes something. Today, swapping one cryptocurrency for another in France generally does not trigger capital gains tax. The tax arrives later, when you sell for euros or buy goods and services with crypto. This amendment ends that deferral for one class of token: stablecoins that qualify as electronic money tokens under the EU's MiCA rules.

What the Amendment Actually Changes

The text rewrites article 150 VH bis of France's general tax code, so the deferral no longer applies when the seller receives an electronic money token as defined in point 7 of paragraph 1 of article 3 of EU regulation 2023/1114.

That is the MiCA definition, and the precision matters. Europe has already moved to keep non-compliant stablecoins off regulated venues, and this amendment is drawn around that same regulatory category rather than around the euro. Stablecoins that are not classified as e-money tokens stay outside its scope. Francois Volpoet, Chainalysis's CEO for France, notes that this leaves USDT, DAI and PAXG untouched.

So the trade that becomes taxable is the compliant version of it. A swap into a token sitting outside MiCA, on a venue that lists it, would not be caught by this amendment as drafted.

The Rate and Who Pays

France applies a 31.4% flat tax to crypto gains when investors cash out or spend their holdings. The amendment removes the deferral rather than setting a rate of its own, so the existing flat tax is what a taxable stablecoin swap would face.

It was tabled by Nicolas Sansu with co-signers from the left-wing GDR group. The parliamentary reasoning is that a gap in the law lets gains converted into fiat-pegged stablecoins escape tax, and the explanatory note says the UK and Italy have already legislated in the same direction. The amendment offsets the cost to the state with an extra levy on tobacco excise, which is how French budget amendments often balance their books.

Volpoet's Warning, and the Evidence Behind It

Volpoet argues the measure works against the goal of pulling more crypto activity into the regulated system. He says it could instead push investors toward DeFi platforms, peer-to-peer trading and exchanges outside international tax-reporting arrangements.

"Do we want more taxpayers to declare their assets, or a higher tax rate applied to a base that is increasingly evaded?"

That is a forecast, not an observed result. Nothing read for this article shows euro stablecoin flows already moving to unregulated venues since the amendment was adopted. Volpoet's case leans on an earlier comparison: European trading volumes for EURC rose far faster than USDC between July 2024 and June 2025, as regulatory changes landed. Same direction, different trigger.

There is a counter-argument from inside the tax profession. Lea Mastrolillo, a lawyer in the tax team at ORWL, calls removing the deferral the wrong answer. The crypto-to-stablecoin exchange, she argues, is the most common operation in decentralised finance, and taxing it would make the trade as hard to declare as it is to control.

Self-Hosted Wallets, Exit Tax and Losses

Four other crypto amendments cleared the finance committee alongside the swap tax.

• Self-hosted wallets: I-CF821 would require taxpayers to declare wallets they hold directly rather than with a service provider, once the value at 31 December reaches €100,000, with a penalty of up to €10,000 for failing to declare. It was tabled by Charles de Courson and deputies from the Libertes, Independants, Outre-mer et Territoires group, and cites a parliamentary inquiry that found €3.5 billion of crypto gains realised in 2021 against €400 million of held assets declared to the DGFiP that year.
• Exit tax: I-CF1822 would bring unrealised gains on crypto assets worth more than €800,000 into France's exit tax, applying to people who move their tax domicile out of the country from 1 January 2027.
• Losses: I-CF798, worked on with the Association pour le Developpement des Actifs Numeriques, would let crypto losses be carried forward or back for 10 years, matching how securities are treated.

The Next Real Test Is a Vote on 20 October

None of this is law. The finance committee adopted the amendments, then rejected the revenue section of the government's 2027 budget by 31 votes to 3, which sends the full Assembly back to the original text. Backers must refile the crypto measures before a vote on the revenue section on 20 October. After that come Senate examination and an adoption expected by 31 December 2026.

That vote is the first honest test of whether the swap tax survives. If it does, the question Volpoet raises becomes the one to watch: whether a rule that taxes the regulated stablecoin and leaves the unregulated one alone does what its authors intend.