Crypto-asset tax in France (actifs numériques)

How France taxes an individual on digital assets: the flat tax on occasional disposals, the option for the progressive scale, the exemption for small yearly proceeds, what counts as a disposal, the habitual and professional cases, mining and staking, foreign account declarations, and the gain formula. Figures are for tax year 2026, meaning disposals made in 2025 and declared in 2026, and disposals made in 2026. The rates, the exemption and the micro-BNC allowance come from the tax administration's own page, modified 17 July 2026. BOI-RPPM-PVBMC-30-10 and -30-20 are in force since 2 September 2019. BOI-RPPM-PVBMC-30-30, in force since 23 April 2024, still prints an older combined rate because it was not rewritten for the 2026 social levy rise, so every rate here comes from impots.gouv.fr.

Based on work by Romain Simon (@romainsimon), licensed under MIT. Adapted for the OpenAccountants format.

France: Crypto-Asset Taxation (Particuliers) v1.0

Section 1: Quick Reference

Field	Value
Country	France
Tax	Income tax plus social levies on gains from disposing of digital assets
Currency	EUR. Another currency is converted at the exchange rate on the day of the operation
Tax year	Calendar year, over the whole foyer fiscal
Primary legislation	CGI, art. 150 VH bis. Rate and scale option in CGI, art. 200 C. Foreign accounts in CGI, art. 1649 bis C
What a digital asset is	Tokens and virtual currencies within CoMoFi, art. L. 54-10-1
Key forms	Annexe n° 2086 (per disposal), déclaration n° 2042-C (boxes 3AN, 3BN, 3CN), imprimé n° 3916-3916 bis (foreign accounts)
Exemption and default rate	See the tables in Section 6 and Section 5
Tax authority	Direction générale des Finances publiques
Verified by	Pending. A French expert-comptable or avocat fiscaliste must sign off

Section 2: Scope: Occasional vs Professional

Three regimes. The first question in any crypto engagement is which the client is in.

• Occasional disposals in private wealth management: CGI, art. 150 VH bis. The regime the rest of this Guide describes. It covers individuals tax-resident in France within CGI, art. 4 B, managing their private wealth, directly or through an interposed person. Disposals of every member of the foyer fiscal are added together. See https://bofip.impots.gouv.fr/bofip/11967-PGP.html
• Habitual buying for resale: BIC. Gains from "l'exercice habituel d'une activité d'achat en vue de la revente d'actifs numériques" stay in industrial and commercial profits. The administration ties this to a commercial activity within Code de commerce, art. L. 110-1.
• Professional-like conditions: BNC, not BIC. Since 1 January 2023 a third case sits between the two: buying, selling or exchanging digital assets "dans des conditions analogues à celles qui caractérisent une activité professionnelle", without it being the client's profession, is taxed as non-commercial profits. The case named is investors making "des opérations nombreuses et sophistiquées" all year with professional traders' tools. They pay the progressive scale plus social levies, with either the micro-BNC allowance in Section 8 or actual expenses under the déclaration contrôlée. Source: the page linked in Section 8.
• Partnerships. A société within CGI, art. 8, art. 8 bis or art. 8 ter, seated in France with a non-professional activity such as holding a portfolio, is an interposed person and each partner is taxed on their share. One with an industrial, commercial, artisanal, agricultural or non-commercial object falls under the professional gains regime instead, whether its disposals are habitual or occasional.

What the official pages do NOT print. No page read here gives a transaction count, a frequency or a share of household income that turns an occasional investor into a habitual or professional one. The only wording given is the "opérations nombreuses et sophistiquées" test above. Treat any rule of thumb as untested.

Section 3: Taxable Events (Fait Générateur)

The taxable event is a disposal for consideration. The doctrine lists four kinds: legal tender money, a good that is not a digital asset, a digital asset exchanged with a soulte, and a service.

Operation	Taxable?	Notes
Source	all figures below	https://bofip.impots.gouv.fr/bofip/11967-PGP.html
Buy digital assets with legal tender money	No	Acquisition only
Sell digital assets for legal tender money	Yes	"de monnaie ayant cours légal"
Pay for a service with digital assets	Yes	"d'un service"
Exchange digital assets for a good that is not a digital asset	Yes	"de l'échange d'un bien autre qu'un actif numérique"
Exchange digital assets for other digital assets, no soulte	No	Sursis d'imposition, CGI art. 150 VH bis, II-A. Intercalary: no taxable event, not declared
Exchange digital assets for other digital assets WITH a soulte	Yes	"l'échange avec soulte entre actifs numériques est une opération imposable"
Digital asset to stablecoin, no soulte	No	A stablecoin is a digital asset within CoMoFi, art. L. 54-10-1
Stablecoin to legal tender money	Yes	A disposal for legal tender money
Mining, staking	Not this regime	See Section 8

• Crypto-to-crypto is a deferral, not an exemption. An exchange without soulte gets a sursis d'imposition: the gain is not cancelled, it is carried in the portfolio and taxed when the client sells for money, a good or a service. The reference is CGI, art. 150 VH bis, II-A, not the paragraph the earlier version cited.
• A soulte breaks the deferral. A cash balancing payment received or paid makes the exchange taxable. A soulte received is added to the disposal price, one paid is deducted.
• Fees paid in crypto. Paying a platform or miner fee in digital assets is consideration for a service, so a taxable operation. As a simplification the disposal and its fees count as one operation with one gain; on a sursis exchange the fees get the same sursis.

Section 4: PAMC Method (Prix d'Acquisition Moyen Pondéré en Continu)

Official formula

CGI, art. 150 VH bis, III sets the gross gain as the disposal price less the product of the total acquisition price of the whole portfolio by the ratio of the disposal price to the total value of that portfolio. The doctrine prints it:

Plus ou moins-value brute = Prix de cession - [Prix total d'acquisition x Prix de cession / Valeur globale du portefeuille]

In English: gain = disposal price, less (total acquisition price x disposal price / portfolio value just before the disposal). See https://bofip.impots.gouv.fr/bofip/11968-PGP.html

The three inputs

• Disposal price. The price received, plus a soulte received, less a soulte paid, then reduced on evidence by the seller's costs of that disposal. Those costs come off the first term only: not off the disposal price used inside the ratio.
• Total acquisition price. Everything paid or given for the portfolio, including consideration in kind and soultes paid. An asset received by inheritance or gift takes the value used for the droits de mutation à titre gratuit, or failing that its real value when it entered the client's estate. Where the client cannot produce the supporting documents for a price or value of acquisition, those assets are deemed acquired for a nil value. The total is then reduced by the fractions of initial capital contained in the price or value of each earlier disposal, whether for consideration or by gift, leaving out exchanges that got the sursis, and by soultes received on earlier exchanges. That stops one cost being counted twice.
• Portfolio value. Every digital asset held by the foyer fiscal before the disposal, valued at that moment, whatever the storage: exchange platforms including foreign ones, personal servers, offline devices. Re-measured at every taxable disposal.

A worked example from the doctrine

What	Value	Note
Source	all figures below	https://bofip.impots.gouv.fr/bofip/11968-PGP.html
January: acquisition price, the client held nothing before	EUR 1,000	"acquiert pour 1 000 € d'actifs numériques"
March: portfolio value before the disposal	EUR 1,200	"la valeur globale de son portefeuille est de 1 200 €"
March: disposal price	EUR 450	"Il réalise alors une cession pour un prix de 450 €"
March: fraction of the acquisition price used against this disposal	EUR 375	The doctrine works 1000 x 450 / 1200
March: the gain	EUR 75	450 less 375

At the next disposal the acquisition price is reduced by the fraction already used, so that figure is carried forward for the life of the portfolio.

Practical consequences

• Each disposal draws on the whole portfolio, not on a chosen lot. It is not FIFO and it is not LIFO.
• It needs the complete history from the first acquisition, and a portfolio valuation at every taxable disposal. Untaxed crypto-to-crypto exchanges still have to be traced, because they move both.

Recommended tools

Koinly, CoinTracking, Waltio and Cryptio are commercial products, not official ones, and no page read here endorses any of them. If one is used, check it applies the formula above, including the reduction for fractions of initial capital, and keep its working.

Section 5: Tax Rates

Default: the prélèvement forfaitaire unique

Component	Rate	Note
Source	all figures below	https://www.impots.gouv.fr/particulier/questions/comment-declarer-les-plus-ou-moins-values-sur-cessions-dactifs-numeriques
Total flat rate on an occasional disposal	31.4%	"prélèvement forfaitaire unique (PFU) de 31,4 %"
Income tax part	12.8%	"12,8 % d'impôt"
Social levies part	18.6%	"18,6 % de prélèvements sociaux"

The total rate above is the one the administration itself prints, whatever the number of transactions. It is charged on the net gain for the year, after this year's crypto losses (Section 7). Do not add the two parts together yourself elsewhere: BOI-RPPM-PVBMC-30-30 still prints an older combined figure.

Which income years the rate above covers. An occasional crypto gain bears the social levies on revenus du patrimoine, not those on produits de placement. The rise in the contribution sociale généralisée brought in by the social security financing law for 2026 applies to revenus du patrimoine from the income of 2025 declared in 2026, and only from 1 January 2026 to produits de placement such as dividends and interest. So the total above is the rate for a disposal made in 2025 and declared in 2026, and for a disposal made in 2026. A lower social levy figure quoted for investment income of 2025 belongs to produits de placement and must not be carried across to a crypto gain. Basis: loi n° 2025-1403, art. 12, and CSS, art. L136-8. See https://www.impots.gouv.fr/www2/fichiers/documentation/brochure/ir_2026/pdf_som/nouveautes.pdf

Option barème (since revenus 2023)

• How it is made. Tick box 3CN. The option must be made expressly on the déclaration d'ensemble des revenus (déclaration n° 2042-C), at the latest before the filing deadline. Made late it does not exist and the flat income tax rate applies. It may still be changed before that deadline. The box is on https://www.impots.gouv.fr/particulier/questions/comment-declarer-les-plus-ou-moins-values-sur-cessions-dactifs-numeriques and the conditions are on https://bofip.impots.gouv.fr/bofip/11969-PGP.html
• What it covers. It is global for all gains of the same year within the flat rate of the first paragraph of CGI, art. 200 C, and irrevocable once the deadline passes. It is NOT the option for investment income: "Cette option est définitive et indépendante de celle qui concerne les revenus de capitaux mobiliers". The earlier version of this Guide said it was shared with dividends and interest. That is wrong.
• Effect. The gains join the net global income taxed on the progressive scale. No page read here prints a marginal rate below which the option always wins, so model it on the client's figures. Basis: loi n° 2021-1900, art. 79.

Section 6: EUR 305 Exemption Threshold

Annual total of disposal prices	Treatment	Note
Source	all figures below	https://www.impots.gouv.fr/particulier/questions/comment-declarer-les-plus-ou-moins-values-sur-cessions-dactifs-numeriques
Not more than EUR 305	Exempt for the year	"n'excède pas 305 € au cours de l'année d'imposition"
More than EUR 305	Every taxable disposal of the year is taxed, the small ones included	See the cliff example below

• Measured on gross proceeds, not on the gain. The test adds up the year's disposal prices, not the profit. A sale of a few hundred euro with a tiny gain still counts its whole price.
• A yearly cliff, not an allowance. Pass it by one euro and the whole year's gain is taxed, not the excess only.
• Measured per foyer fiscal, adding disposals made directly and through an interposed person, counting every consideration: money, a good, a service. For a disposal through an interposed person, count the client's share of the disposal price. Crypto-to-crypto exchanges without soulte are left out.
• Exempt does not mean nothing to file. Each disposal price still goes on the annexe. Only the gain calculation is dropped.

The cliff, as the doctrine's own examples show it

Case	Value	Note
Source	all figures below	https://bofip.impots.gouv.fr/bofip/11967-PGP.html
Three disposals, each of	EUR 100	"un montant de 100 € chacune"
Those three added up, under the limit, so exempt	EUR 300	"est de 300 € (3 x 100 €)"
Their gain, not taxed	EUR 90	"s'élève à 90 €. Ainsi, le contribuable est exonéré"
Four disposals of the same size, added up, over the limit	EUR 400	"est de 400 € (4 x 100 €)"
Their gain, taxed in full	EUR 120	"s'élève à 120 €. Ainsi, le contribuable est imposé"

Section 7: Loss Offsetting

• Within the year, yes. Losses on taxable disposals of digital assets are set against gains on such disposals in the same year. The net figure is taxed.
• Against other assets, no. A crypto loss "n'est pas imputable sur les plus-values de cession d'autres biens", securities included.
• Carry forward, no. A net loss for the year is lost: "elle ne se reporte pas sur les années suivantes". Source: the page linked in the rate table in Section 5.
• Losses before 2019 are dead. Losses on disposals before 1 January 2019 cannot be set against any later gain. See https://bofip.impots.gouv.fr/bofip/11968-PGP.html

Section 8: Staking, Mining, Airdrops

Mining and staking are NOT capital gains. They are taxed on the nature of the activity, and the administration puts both in non-commercial profits.

Activity	Category	Note
Source	all figures below	https://www.impots.gouv.fr/particulier/questions/comment-declarer-les-plus-ou-moins-values-sur-cessions-dactifs-numeriques
Mining (minage)	BNC	"Les bénéfices issus des activités de minage ou de staking sont imposés dans la catégorie des bénéfices non commerciaux (BNC)"
Staking	BNC	Same sentence
Micro-BNC allowance, printed for the professional-conditions case in Section 2	34%	"un abattement de 34 % (régime micro‑BNC)"
Actual expenses instead, same case	Déclaration contrôlée	"soit la déduction des frais réels"
Habitual buying to resell, as a commercial activity	BIC	Section 2
Professional-like conditions	BNC	Section 2

• Why BNC and not BIC for mining. The doctrine applies the non-commercial category, by exception, where the gains are not a capital return on an investment but the consideration for taking part in the creation or operation of the virtual unit-of-account system. See https://bofip.impots.gouv.fr/bofip/11967-PGP.html The earlier version of this Guide put mining in BIC. That is wrong.
• These receipts are taxed on the progressive scale plus social levies, not at the flat rate in Section 5. Value them in euro at each receipt date. A later sale of a mined or staked coin is a separate event, under Section 4.
• Airdrops: no position here. No page read here states how an airdrop is taxed on receipt, or whether a task performed changes that. Do not state a rule.

Where the allowance above comes from. The page prints it for the professional-conditions case, in the sentence before the one that puts mining and staking in non-commercial profits. It does not say in terms that a miner or a staker takes the same allowance. Micro-BNC is the ordinary regime for small non-commercial receipts, so it will usually be open to them, but that last step is an inference and not the page's words.

The micro-BNC regime has a ceiling

Item	Value	Note
Source	all figures below	https://entreprendre.service-public.fr/vosdroits/F23267
Receipts ceiling for the micro-BNC regime, income received in 2026, tested on 2025 or on 2024, so the regime is lost only where both years are over	EUR 83,600	"Activité libérale (BNC) … n’a pas dépassé 83 600 €"

Section 9: Form 2086 (Mandatory Disclosure)

• What goes where. Online, fill annexe n° 2086 at step 3 under "Déclarations annexes"; the total carries itself into box 3AN for a gain or 3BN for a loss. On paper, enter it in box 3AN of the déclaration n° 2042-C, or 3BN for a loss, and attach the annexe. See https://www.impots.gouv.fr/particulier/questions/comment-declarer-les-plus-ou-moins-values-sur-cessions-dactifs-numeriques
• One line per taxable disposal. Each line carries the disposal price with any costs and any soulte received or paid, the acquisition price split into acquisition prices and fractions of initial capital, soultes received on earlier exchanges, the portfolio value at the moment of the disposal, and that disposal's gain or loss. The annexe then shows the year's gains and losses added together. Basis: CGI, ann. III, art. 41 duovicies J. See https://bofip.impots.gouv.fr/bofip/11969-PGP.html
• Exempt year, reduced filing. Where Section 6 exempts the year, only the price of each disposal, with its costs and any soulte, goes on the annexe. Sursis exchanges are not declared at all. Through a partnership, the interposed person files its own annexe plus the split between partners, and the individual reports only their share and that person's identity.
• Foreign accounts must be declared. Anyone domiciled in France holding a digital-asset account with a provider established abroad declares it with the income tax return, under CGI, art. 1649 bis C. Online it is asked at the end; on paper use the imprimé n° 3916-3916 bis. It covers accounts opened, held, used or closed in the year, so a closed one is still declared.

Fines for a foreign digital-asset account that is not declared

Case	Fine	Note
Source	all figures below	https://bofip.impots.gouv.fr/bofip/11969-PGP.html
Per account not declared	EUR 750	"amende de 750 € par compte non déclaré"
Per omission or inaccuracy	EUR 125	"125 € par omission ou inexactitude"
Cap per declaration	EUR 10,000	"dans la limite de 10 000 € par déclaration"
Accounts worth more than this at any moment in the year: fines double	EUR 50,000	"est supérieure à 50 000 € à un moment quelconque de l'année"
Then, per account not declared	EUR 1,500	"1 500 € par compte non déclaré (au lieu de 750 €)"
Then, per omission or inaccuracy	EUR 250	"250 € par omission ou inexactitude (au lieu de 125 €)"

The doubling test is market value at any moment in the year, not value at 31 December and not the gain.

Section 10: Documentation Requirements

The client must be able to rebuild the whole portfolio history: the formula in Section 4 needs the acquisition price and the portfolio value at every taxable disposal. Keep:

• The complete transaction history from every platform and wallet, exported.
• Proof of the date and price of every acquisition, including gifts and inheritances and the value used for the droits de mutation à titre gratuit.
• Crypto-to-crypto exchanges, untaxed though they are, because they move the acquisition price and the portfolio value, and wallet-to-wallet transfers, showing a movement was not a disposal.
• A portfolio valuation at each taxable disposal, covering every holding of the foyer fiscal on every platform, server and offline device.
• Mining and staking receipts valued in euro at each receipt date, and the exchange rate used for anything not in euro.

No page read for this Guide prints a retention period. The earlier version stated one. It has been removed rather than guessed at.

Section 11: Conservative Defaults

Ambiguity	Default
Activity classification unclear	Occasional private wealth management, CGI art. 150 VH bis. Document why
Flat rate or scale unclear	The flat rate in Section 5: the scale option is irrevocable after the deadline
Stablecoin to stablecoin, no soulte	Not a taxable event, it is a crypto-to-crypto exchange
A fee paid in crypto	Treat the sale and its fees as one operation, as the doctrine allows
Whether a foreign account must be declared	Declare it. The Section 9 fines are per account; filing costs nothing
Acquisition price cannot be evidenced	Those assets are deemed acquired for a nil value, so the whole disposal price is gain. Tell the client before filing, and keep looking for the evidence
Airdrop received	No official page read here sets a rule. Refer

Section 12: Key Legal References

Rule	Reference
Occasional disposals by individuals; residence	CGI, art. 150 VH bis; CGI, art. 4 B
Sursis; exemption; gain formula; portfolio value	CGI, art. 150 VH bis, II-A; II-B; III; III-C
Flat income tax rate and the option for the scale	CGI, art. 200 C
What a digital asset is	CoMoFi, art. L. 54-10-1, and art. L. 552-2 for tokens
Content of the annexe to the return	CGI, ann. III, art. 41 duovicies J and K
Foreign digital-asset accounts, and the fines	CGI, art. 1649 bis C and art. 1736, X
Commercial activity, for the BIC case	Code de commerce, art. L. 110-1
Statutes: the regime, then the scale option	loi n° 2018-1317, art. 41; loi n° 2021-1900, art. 79
Doctrine: scope, tax base, charge and filing	BOI-RPPM-PVBMC-30-10, -30-20, -30-30
Social levies on revenus du patrimoine, and the rate rise	CSS, art. L136-8; loi n° 2025-1403, art. 12
Doctrine: mining and staking in non-commercial profits	BOI-BNC-CHAMP-10-10-20-40

The method, step by step

1. Place the client in one of the three regimes in Section 2. Habitual buying for resale as a commercial activity within Code de commerce, art. L. 110-1 is BIC. Conditions analogous to a professional activity are BNC. Everything else in private wealth management is CGI, art. 150 VH bis, at https://bofip.impots.gouv.fr/bofip/11967-PGP.html If BIC or BNC, stop: Sections 4 to 7 do not apply.
2. List every operation of the year for the whole foyer fiscal and mark each taxable or not, using Section 3. Sales for money, payments for goods or services and exchanges with a soulte are taxable. Exchanges between digital assets without a soulte are not, and are not declared. Then add up the taxable disposal prices and test the exemption in Section 6: at or under the limit the year is exempt and only the prices are filed; over it, every taxable disposal is taxed. Same page as step 1.
3. Build the running portfolio record and compute each disposal with the formula in Section 4, then add the year's gains and losses to one net figure. The acquisition price runs from the first ever acquisition, less fractions of initial capital already used and soultes received. The portfolio value is taken at each taxable disposal across every platform and wallet of the foyer fiscal. See https://bofip.impots.gouv.fr/bofip/11968-PGP.html
4. Choose the rate. The flat rate in Section 5 applies by default. Model the progressive scale on the client's numbers, and if it wins tick box 3CN on the déclaration n° 2042-C before the deadline. It is irrevocable afterwards and separate from the option for investment income. The box is on https://www.impots.gouv.fr/particulier/questions/comment-declarer-les-plus-ou-moins-values-sur-cessions-dactifs-numeriques and the conditions are on https://bofip.impots.gouv.fr/bofip/11969-PGP.html
5. File annexe n° 2086, one line per taxable disposal, total carried to box 3AN or 3BN of the déclaration n° 2042-C. See https://www.impots.gouv.fr/particulier/questions/comment-declarer-les-plus-ou-moins-values-sur-cessions-dactifs-numeriques
6. Declare every foreign digital-asset account opened, held, used or closed in the year, on the imprimé n° 3916-3916 bis or at the end of the online return, under CGI, art. 1649 bis C. Fines are in Section 9, sourced there.

Ask the client first

• How do you actually trade: bots, arbitrage, professional traders' tools, and how often? This decides between CGI art. 150 VH bis, BIC and BNC, and changes the rate, the forms and the social charges.
• Did anyone else in your household sell, spend or exchange digital assets this year? The exemption and the portfolio value cover the whole foyer fiscal.
• Did you pay for anything with crypto, swap crypto for a physical item, or take cash on top of a swap? Each is a taxable disposal clients rarely report.
• Do you have every platform and wallet export back to your first purchase, including swaps you never cashed out? Without them the acquisition price cannot be built.
• Do you hold an account with a platform established outside France, including one opened and closed this year? A separate declaration, with its own fines.
• Did you receive coins from mining, staking, a gift or an inheritance? Mining and staking are BNC income at receipt; a gift or inheritance has its own acquisition value.

When to refuse or refer

• The client is habitual or professional (BIC or BNC). This Guide covers the occasional regime only: profits, expenses, VAT and social contributions are all outside it.
• The acquisition history cannot be rebuilt. The doctrine then treats the missing acquisitions as made for a nil value, which taxes the whole price. Say that to the client before filing, and refer where the sums are large.
• Airdrops, hard forks, lending rewards, liquidity pool rewards, NFTs and other DeFi positions. No page read here sets a rule for them.
• The client is not tax-resident in France within CGI, art. 4 B, or moved in or out during the year. Residence and any treaty come first.
• Digital assets held through a company, or a partnership with a commercial object: professional gains regime. Tokens that are financial instruments within CoMoFi, art. L. 211-1 are outside the digital-asset definition.
• Past years not declared, or any question turning on a figure this Guide does not print, such as a retention period or a professional-activity test.

Sources

• https://www.impots.gouv.fr/particulier/questions/comment-declarer-les-plus-ou-moins-values-sur-cessions-dactifs-numeriques
• https://bofip.impots.gouv.fr/bofip/11967-PGP.html
• https://bofip.impots.gouv.fr/bofip/11968-PGP.html
• https://bofip.impots.gouv.fr/bofip/11969-PGP.html

Disclaimer: This Guide is for informational purposes only and does not constitute tax advice. All positions must be reviewed and signed off by a qualified expert-comptable or avocat fiscaliste before filing.

Contributed by OpenAccountants.