France to tax BTC-USDC swaps from 2027 under new amendment

France’s proposed crypto tax overhaul would make certain Bitcoin or Ether-to-stablecoin swaps taxable disposals from Jan. 1, 2027, even when investors keep the proceeds in a wallet or exchange account. The National Assembly’s Finance Committee adopted amendment I-CF1826 on Oct. 7, with plenary discussion listed for Oct. 13. USDC is a concrete example because Circle identifies its European version as an e-money token under MiCA.

Why it matters

Under current French tax authority guidance, qualifying crypto-to-crypto exchanges without a cash balancing payment generally receive tax deferral. Converting crypto into fiat, or using it to buy goods or services, can already trigger taxation under the private-disposal regime. The amendment would remove that deferral when the asset received is an e-money token covered by MiCA, whose definition includes crypto-assets designed to maintain stable value against one official currency.

For an investor moving Bitcoin exposure into USDC to reduce risk, the swap itself could become the taxable event. The gain would be calculated from the euro value received above the relevant acquisition basis, even though no money has reached a bank account. The wording targets the asset received and does not include an express issuer-licensing condition.

Market impact

The proposal would also replace the current portfolio-wide acquisition-cost allocation for new disposals with asset-specific basis rules and weighted-average acquisition values for holdings of the same nature. Investors holding assets before 2027 could use evidenced actual costs or allocate the old portfolio basis across holdings at Dec. 31, 2026. That choice would be irrevocable for the entire portfolio when the first post-2027 taxable disposal is reported.

In the proposal’s example, Bitcoin bought for €20,000 and worth €60,000 could produce either a €40,000 gain using actual cost or a €24,000 gain under the allocation route. USDC received in the swap would receive a €60,000 basis, preventing the same gain from being recognized again if its euro value were unchanged when later sold. Loss timing remains important because French crypto losses offset gains in the same tax year but cannot be carried into later years. Investors would need acquisition records, weighted averages and transition-date valuations if the measure advances.