French Finance Committee Backs Taxable Bitcoin-to-Stablecoin Swaps From 2027

Taxable Stablecoin Swaps From 2027

The French National Assembly's Finance Committee approved amendment I-CF1826 on Wednesday, October 7, during its review of the 2027 budget bill. The amendment, submitted by lawmaker Nicolas Sansu, would make conversions of cryptocurrencies into qualifying electronic money tokens taxable transactions from January 1, 2027, per the official amendment record. Under current French rules, in place since 2019, swapping one digital asset for another is not a taxable event, which means Bitcoin price gains currently escape tax when the asset is converted into a stablecoin instead of sold for euros; tax falls due only on conversion into fiat or on purchases of goods and services. Sansu's proposal removes that exemption for exchanges in which investors receive electronic money tokens as defined under the EU's Markets in Crypto-Assets Regulation. The amendment's explanatory statement argues the status quo lets investors convert appreciated assets into fiat-backed tokens without triggering the tax a direct sale would, even though such tokens can be used for payments and to buy other crypto. Covered gains or losses would be calculated as the disposal value minus the acquisition cost, with documented transaction expenses deductible. For assets bought before January 1, 2027, investors could use documented purchase prices or allocate the portfolio's total acquisition cost as of December 31, 2026 across holdings by value, choosing irrevocably when filing their first return. The push to tax at the conversion point originated inside France's own digital asset sector: executives including Deblock CEO Jean Meyer, Lyzi co-founder Damien Patourot and Waltio CEO Pierre Morizot proposed it as a way to simplify filings and promote token-based payments. Committee approval is not final law; plenary debate runs October 13 to 19, with the budget vote set for November 17.

Loss Relief and an Exit Tax

A second amendment adopted the same day, I-CF798, filed by Daniel Labaronne, would allow qualifying capital losses on digital asset disposals to be carried forward for up to 10 years and offset against gains realized in that period. Present law limits losses to gains arising in the same tax year, after which unused amounts expire. The relief concerns realized losses only and provides no direct compensation for holders whose assets have fallen in value. A third measure, amendment I-CF1822, also from Sansu and adopted on Thursday, October 8, would extend France's existing exit tax to unrealized gains on qualifying crypto holdings above €800,000 when taxpayers move their tax residence abroad. Lawmakers rejected a proposal to extend the wealth tax to digital assets, while other amendments, including mandatory reporting for self-custody crypto wallets above €100,000 and fines on platforms, remain under review; in a self-custody setup the holder keeps the private key rather than custody assets with a service provider. The amendments land as France prepares for the EU's DAC8 directive, in force since January 1, 2026, which obliges crypto service providers to collect customer and transaction data, with information covering 2026 to be exchanged between tax authorities in 2027. France's Council of State rejected an emergency challenge to the implementing decree on September 17, filed by Bull Bitcoin (BTC) and Paymium, though a separate annulment case remains pending. The fiscal stakes are sizable: Chainalysis estimated $9.4 billion in potentially taxable French digital asset activity during 2025, including $2.5 billion in realized gains, while French taxpayers declared €368 million in crypto capital gains for 2024 across roughly 24,000 filings.

The distinction written into the amendment texts is between a proposal and a law: nothing in I-CF1826 binds anyone until the full National Assembly votes, and the January 1, 2027 start date depends on that process clearing. If it clears, the stablecoin leg of a trade, currently a non-event, becomes a disposal, which lands hardest on traders who park gains in tokens between spot trading sessions. Industry association ADAN counters that tax is payable only in euros, so taxing the conversion step could push flows toward unregulated dollar-based tokens, the opposite of what the French firms that backed the measure intended. Read alongside the deficit arithmetic, a 2027 gap projected above 5% of GDP and a 10-year bond yield at a 25-year high, the committee's choices point one way: a widening tax perimeter around digital assets.