France's Finance Committee has reviewed a package of crypto-tax amendments during its work on the country's 2027 budget, opening a debate over when a cryptocurrency gain becomes sufficiently real to tax—even if the investor has never sent euros to a bank account. The package contains three separate measures: one that could make swaps into regulated fiat-linked tokens taxable from 2027, another that could pull large crypto portfolios into France's exit-tax system when a holder moves abroad, and a third that would extend the loss carry-forward period to 10 years. None of the proposals has yet changed the current rules.

Two Proposed Tax Triggers

The amendments examined by the committee centre on two distinct events:

• Crypto to a regulated e-money token: a gain could be calculated when a holder swaps into an eligible fiat-linked token.
• France to another tax residence: large unrealised gains could be assessed when a taxpayer leaves the country.

The two events are not the same. The first concerns a transaction inside a portfolio; the second concerns the point at which France may lose the right to tax a future sale.

Stablecoin Swaps as Taxable Exchanges

Amendment I-CF1826 would change the treatment of exchanges into electronic-money tokens (EMTs) from January 1, 2027. Under MiCA, the European Union's crypto-asset regulation phased in across the bloc during 2024, an EMT is defined as a crypto asset designed to maintain its value by referencing a single official currency—a wording narrower than the catch-all term "stablecoin." The draft refers specifically to MiCA electronic-money tokens, a category that generally covers regulated euro- or dollar-linked tokens. A token marketed as stable would not automatically fall within the rule.

In practice, a Bitcoin holder who swaps BTC for an eligible dollar-linked token could need to calculate the gain on that trade, even though no cash has entered a bank account. That tax-point question is not unique to France: in the United States, IRS guidance dating back to 2014 treats any exchange of one crypto asset for another as a taxable disposal, meaning token-to-token trades can trigger tax even when no fiat changes hands.

The amendment's explanatory note argues that a swap into a fiat-pegged token currently allows a gain to remain untaxed for longer than a direct conversion into fiat currency; the proposed change would move that tax point forward.

The text also presents long-term holders with a record-keeping decision. They could either document the historic cost of each asset or opt for a one-time, irreversible method of allocating the portfolio's total acquisition cost—a choice that would affect the taxable gain on any later eligible swap.

Unrealised Gains on Departure

Amendment I-CF1822 takes a different route: it would fold crypto assets into France's exit-tax framework when a taxpayer changes residence. The measure would apply to people who have been French tax residents for at least six of the previous 10 years and whose household crypto portfolio exceeds €800,000 at the time of departure.

The draft covers assets held directly, through a crypto-asset service provider, or through another third party—a formulation that places self-custodied wallets inside the proposed calculation.

The assessment would be based on unrealised gains at the moment a person leaves France. Rather than treating every departure as an immediate sale of crypto, the amendment adapts the existing exit-tax framework, including its deferral and relief mechanisms. The residency and value conditions also mirror the thresholds France already applies to shares and other securities under that regime.

The stated purpose is that a large gain should not automatically escape French tax jurisdiction simply because the holder moves before selling. Whether that approach survives the parliamentary process is a separate question.

A Longer Life for Crypto Losses

The package is not focused solely on earlier recognition of gains. Amendment I-CF798 would allow losses on crypto disposals to be carried forward for 10 yearsn
That could help investors whose gains and losses fall in different tax years. Someone who paid tax after a profitable year and then realised losses during a later market decline would have more time to offset those losses against future taxable gains.

Taken together, the three measures serve separate functions: one alters the treatment of a specific type of swap, another concerns departure from France, and the third changes how losses are treated after disposal.

Committee Vote Leaves Current Rules Untouched

France has not introduced a new stablecoin tax or a crypto exit tax. On October 9, the Finance Committee rejected the revenue section of the 2027 budget as a whole after reviewing and voting on individual amendments. LCP, the National Assembly's parliamentary channel, reported that the section failed by 31 votes to three, with two abstentions.

When the full Assembly begins its debate on October 13, it will return to the government's original budget text. The crypto measures could then be tabled again, rewritten or dropped entirely—and even if retabled and adopted, they would form part of a budget bill that still has to complete its passage through Parliament before taking effect.

For holders, the immediate rules remain unchanged. The bigger shift is political: lawmakers are now openly debating whether moving into regulated digital money—or moving abroad—should carry tax consequences similar to cashing out.

This article is for informational purposes only and does not constitute tax or legal advice. Taxpayers should consult a qualified professional regarding their individual circumstances.