France Proposes Crypto Exit Tax on Cryptocurrency Holdings Above €800,000

France is considering extending its existing exit tax regime to cryptocurrency holdings worth more than €800,000, potentially bringing digital assets within the scope of rules that apply when individuals transfer their tax residence abroad. The proposal was approved by the French National Assembly’s Finance Committee during its review of the 2027 budget, but it has not become law.

The amendment would target unrealised capital gains on crypto-assets held by certain taxpayers leaving France from January 1, 2027. However, the legislative process remains uncertain: the committee subsequently rejected the budget’s revenue section, meaning the amendment would need to be tabled again during the debate in the full National Assembly.

France Targets Unrealised Gains on Crypto Holdings

The proposed measure would extend France’s existing exit tax framework to cryptocurrency portfolios exceeding €800,000 in total value. It would apply to taxpayers who had been French tax residents for at least six of the ten years preceding their departure.

Under the amendment, the relevant tax would be calculated on unrealised gains rather than the total value of the crypto portfolio. The calculation would compare the portfolio’s market value at the time of departure with its acquisition cost.

The proposal would cover crypto-assets held directly, through service providers or other third parties. It would also include assets stored in foreign accounts and self-custody wallets, where investors retain direct control over their private keys.

The €800,000 threshold would apply to the combined crypto holdings of the taxpayer’s household. The proposal therefore concerns the value of the assets and the gains accrued before departure, rather than simply imposing a tax on every investor who moves abroad.

How the Proposed Exit Tax Would Work

The amendment seeks to align the treatment of crypto-assets more closely with the existing rules for securities and certain company-related holdings.

France’s current exit tax can apply when eligible taxpayers transfer their tax residence abroad while holding securities above specified thresholds. Under the proposed extension, qualifying cryptocurrency holdings would also be assessed for unrealised gains at the time of departure.

The amendment would use the existing framework for calculating gains and managing payment deferrals, adapted to the characteristics of crypto portfolios.

Under France’s existing rules, eligible taxpayers moving to another EU member state or certain countries covered by tax cooperation and recovery arrangements may qualify for an automatic payment deferral. Departures to other jurisdictions can require an application, a French tax representative and a financial guarantee.

The existing regime also provides for relief under specified conditions if assets are retained for the applicable holding period. The proposed crypto extension would adapt these arrangements to digital assets, including provisions for partial disposals.

The exact application of the rules to crypto-assets would depend on the final legislative text and implementing provisions. Investors should not assume that every detail of the existing securities regime would automatically apply in an identical way.

Self-Custody Wallets Would Also Be Covered

A notable feature of the proposal is its explicit inclusion of self-custody wallets.

Investors who hold cryptocurrencies in personal wallets would not be excluded merely because their assets are held outside a regulated exchange or traditional financial institution. The amendment would require qualifying taxpayers to declare their crypto holdings, including assets held abroad or in self-custody, when filing the relevant documentation.

This approach reflects a broader challenge for tax authorities: cryptocurrencies can be transferred across borders without the involvement of conventional banks or investment platforms.

For investors planning to relocate, the distinction between exchange-based custody and self-custody would therefore not necessarily remove the potential tax reporting obligation.

The proposal also raises practical questions about valuation, documentation and the calculation of acquisition costs across multiple wallets and platforms. These issues could become particularly important for investors who have accumulated digital assets over several years or transferred holdings between different forms of custody.

Stablecoin Transactions Face a Separate Tax Proposal

The committee also approved a separate amendment concerning exchanges of cryptocurrencies for certain stablecoins linked to a single official currency.

Under the proposed change, qualifying crypto-to-stablecoin swaps would be treated as taxable disposals from January 1, 2027, rather than retaining the tax deferral currently available for exchanges between crypto-assets in the relevant circumstances.

Stablecoins are digital tokens designed to maintain a relatively stable value against a reference currency, such as the euro or US dollar. They are frequently used by crypto investors to reduce exposure to market volatility without immediately transferring funds into a conventional bank account.

The proposed change could affect investors who routinely move from volatile cryptocurrencies into euro- or dollar-linked tokens as part of their portfolio management.

However, this amendment is also subject to the legislative process. Its final scope, treatment of different stablecoins and effective date would depend on the text ultimately adopted by Parliament.

Parliamentary Uncertainty Puts the Proposals on Hold

The Finance Committee’s votes do not mean the measures are now part of French tax law.

On October 9, the committee rejected the 2027 budget’s revenue section as a whole. As a result, the committee-approved amendments were not automatically carried into the version of the bill considered by the full National Assembly.

The parliamentary debate on the revenue section is scheduled to open on October 13, with a vote planned for October 20. Supporters would need to reintroduce the measures and secure the necessary support through the subsequent legislative process.

France’s wider budget debate is taking place amid pressure to reduce the public deficit and manage rising government borrowing costs. Tax proposals affecting cryptocurrency investors are one part of a broader discussion over public revenue, fiscal policy and the treatment of different forms of wealth.

The government’s final budget decisions will determine whether the proposed measures advance, change or disappear from the legislation.

Implications for Crypto Investors in France

If adopted, the proposed exit tax could become a relevant consideration for high-value crypto investors planning to leave France.

The potential impact would depend on several factors, including the size of an investor’s portfolio, the unrealised gains accumulated before departure, the destination country and the availability of payment deferrals or other relief.

The proposal could also increase the importance of maintaining accurate records of acquisition costs, transactions and wallet balances. Investors with assets spread across exchanges, hardware wallets and decentralised platforms may face additional administrative complexity when establishing their tax position.

Nevertheless, the measure remains a proposal. Investors should distinguish between committee approval and enacted legislation before making decisions about relocation, portfolio restructuring or tax planning.

What Comes Next for French Crypto Tax Policy?

The upcoming parliamentary debate will be decisive in determining whether the exit tax amendment returns to the 2027 budget and progresses further.

The stablecoin proposal and other crypto-related amendments may also be reconsidered as lawmakers debate the treatment of digital assets. Their eventual status will depend on the votes and the final text of the legislation.

For Europe’s cryptocurrency sector, the French debate illustrates the continuing effort by national authorities to adapt tax rules to assets that can be held and transferred outside traditional financial institutions.

The central issue is not simply whether crypto holdings should be taxed, but when gains become taxable, how cross-border transfers should be treated and what reporting obligations investors must meet.

For now, France’s proposed €800,000 crypto exit tax remains a legislative proposal rather than an enacted rule.

Source: IMI Daily; French National Assembly legislative documents. This article is for informational purposes and does not constitute tax or legal advice.