French committee backs amendment to tax Bitcoin-to-USDC swaps before cash-out
In brief
- France's Finance Committee adopted amendment I-CF1826 on Oct. 7; it isn't law yet.
- Bitcoin or Ether swaps into MiCA e-money tokens would become taxable disposals.
- USDC is identified as a MiCA e-money token in Circle's European white paper.
- Weighted-average acquisition value would replace portfolio-based cost basis under the amendment.
- Disposals and exchanges from Jan. 1, 2027 would fall under the rules, if enacted.
What changes for stablecoin swaps
Under current French tax authority guidance, covered crypto-to-crypto exchanges without a cash balancing payment get tax deferral. Converting into fiat (or using crypto to obtain other goods or services) can already be taxable under France's private-disposal regime, subject to its applicable exemption.
CF1826 would remove that exchange deferral when the investor receives e-money tokens as defined by the EU's Markets in Crypto-Assets (MiCA) regulation, or related rights. MiCA describes an e-money token as a crypto-asset that seeks to maintain stable value by reference to one official currency. CryptoSlate noted the amendment invokes that definition without an express issuer-licensing condition, and that Circle's European white paper identifies USDC as an e-money token under the same MiCA provision.
That's where the change bites for anyone parking gains in stablecoins.
A gain could become reportable while the proceeds remain in a crypto wallet or exchange account.
The amendment's sponsors don't see the current treatment as intended policy. They described deferral on fiat-backed stablecoin conversions as a legislative loophole.
A new way to calculate gains
The second half of the amendment deals with cost basis. France's existing portfolio-based calculation allocates part of the acquisition price of the entire crypto portfolio to each taxable disposal (current guidance deducts total portfolio acquisition price multiplied by the ratio of disposal price to portfolio value immediately before the transaction).
The proposed replacement would focus on the crypto-assets actually disposed of. For assets of the same nature bought at different prices, it specifies weighted-average acquisition value.
Choosing a transition route
Holdings acquired before 2027 get two routes, per CryptoSlate's reading of the text. Investors could use evidenced actual acquisition costs, determined under the new basis rules. Or they could take the portfolio acquisition price calculated under the old rules at Dec. 31, 2026 and allocate it among the assets they hold on that date, in proportion to their values then.
It's a one-shot decision. The text makes the choice irrevocable for the entire portfolio once the first return reporting a taxable disposal after Jan. 1, 2027 is filed.
Frequently asked questions
Would swapping Bitcoin for USDC be taxable in France under the proposal?
According to CryptoSlate, amendment I-CF1826 would remove tax deferral when an investor receives MiCA-defined e-money tokens. Circle's European white paper identifies USDC as an e-money token under that MiCA provision. A gain could become reportable while proceeds stay in a crypto wallet or exchange account.
When would France's new crypto tax rules take effect?
The Finance Committee adopted the amendment on Oct. 7, but it isn't law. If enacted, the provision would apply to disposals and exchanges from Jan. 1, 2027.
How would cost basis change for French crypto investors?
France currently allocates part of the whole portfolio's acquisition price to each taxable disposal. The proposed replacement would focus on the assets actually disposed of, using weighted-average acquisition value for the same assets bought at different prices. For pre-2027 holdings, investors would choose between two transition routes, and that choice would be irrevocable.
