France’s National Assembly finance committee adopted an amendment to the 2027 budget bill on October 8 that would bring crypto-assets within the country’s exit tax, a charge on unrealized gains levied when a resident moves his tax residence abroad. It would apply to households holding crypto-assets worth more than €800,000 (approximately US$896,000), for departures from January 1, 2027.
The amendment has yet to clear the Assembly. Under Article 42 of the Constitution, the full chamber debates a finance bill in the form the government submitted it, so amendments adopted in committee have to be voted on again on the floor.
The committee also rejected the first part of the bill, which covers revenue, as a whole on October 9, by 31 votes to three with two abstentions, according to La Chaîne parlementaire (LCP), the parliamentary channel.
The vote came in a week when France’s ten-year borrowing cost neared 5%, the highest since 2002, according to Euronews. Public debt stood at 119% of GDP at the end of June, and the government’s bill seeks about €54 billion (approximately US$60.5 billion) in savings and new revenue to bring the deficit to 5% of GDP in 2027.
Philippe Juvin, the committee’s general rapporteur, estimated that the week’s votes would widen the 2027 deficit by about €10 billion (approximately US$11.2 billion), to as much as 5.4% of GDP, according to LCP.
Floor debate opens on October 13, and the Assembly’s calendar sets the vote on the revenue part for October 20. Neither the exit tax measure nor a companion amendment on stablecoins, crypto-assets designed to hold a stable value, was in the bill that Prime Minister Sébastien Lecornu’s government introduced on October 1.
The amendment
Communist deputy Nicolas Sansu and 16 colleagues from the left-wing Gauche démocrate et républicaine group filed the amendment, which would insert a new Article 167 ter into the General Tax Code (Code général des impôts).
It covers taxpayers who were French tax residents for at least six of the ten years before departure and whose households hold crypto-assets worth more than €800,000 in total. An investor who has lived in France for less than six years when he leaves falls outside its ambit, as he does under the existing exit tax.
The €800,000 test applies to the total value of the household’s holdings. The tax itself falls on the unrealized gain: Market value on the day of departure, less total acquisition cost. An unrealized loss on the crypto portfolio at departure could not be set against unrealized gains on securities under the existing exit tax, or carried forward.
The amendment covers crypto-assets held directly or through a service provider or other third party. A departing taxpayer would have to file a statement of all of them, including those in foreign accounts and in self-custody wallets, which the holder controls without an intermediary.
“Self-custody gives you control of your Bitcoin. Tax obligations still attach to the person holding it,” said Adam Juchniewicz, CEO of Bitcoin Lawyer. “Your custody strategy and your jurisdictional strategy have to work together.”
The amendment prescribes no rate and is silent on social charges, the levies that fund France’s social security system. It applies the calculation rules of the existing exit tax on securities, which France charges at 31.4% this year: 12.8% income tax plus 18.6% in social charges. The text leaves open whether the social charges would apply to crypto.
The authors contend in their explanatory note that a person can leave France today with several million euros in crypto-assets and owe nothing on the unrealized gain, while a holder of securities of the same value would pay, a disparity they call a breach of equality before taxation.
An exit tax “may preserve a government’s claim on existing gains while making the jurisdiction less attractive to future investors,” Juchniewicz said. “That is the trade-off France needs to examine.”
“Bitcoin holders planning where to live will weigh the rules for arriving, building wealth, and eventually leaving,” he added. “Predictability matters at every stage.”
Deferral and relief
The existing exit tax applies to departing taxpayers whose securities are worth more than €800,000 or who hold at least 50% of the rights to a company’s profits.
Payment is deferred automatically when the taxpayer moves to another EU member state, or to a country that has agreements with France on administrative assistance and on tax recovery, according to the tax administration’s guidance. The guidance lists the United Kingdom, the United States, and Norway among them.
A taxpayer moving anywhere else must apply for deferral before departure. He must also appoint a tax representative in France and post a guarantee equal to 12.8% of the gains.
France extinguishes the liability if the taxpayer still holds the securities when a holding period expires: Two years after departure, or five years where the portfolio was worth more than €2.57 million (approximately US$2.88 million).
The amendment would extend the same rules to crypto portfolios, with adjustments. A swap of one crypto-asset for another, with no cash changing hands, would not count as a sale, and a taxpayer who sold part of his portfolio early would owe a proportionate share of the tax.
A holder who moves within the EU and keeps his portfolio through the holding period would see the tax canceled, while one who moves to a country without those agreements would have to pay on departure or post the guarantee to defer.
“A second citizenship creates options about where you can build your life,” Juchniewicz said. “Exercising those options requires an understanding of tax residence, departure obligations, and timing. France’s proposal reinforces why citizenship planning and tax planning belong in the same conversation.”
David Lesperance, Managing Director of Lesperance & Associates, says that “proposals in France often are never confirmed by the legislature in law.”
He does note, however, that “crypto holders should watch this closely and look to swap crypto holdings to stablecoins before such swaps are considered taxable events. Like many proposals in many countries, those who advocate such changes forget that the targets have agency and can generally act much faster than lawmakers.”
Stablecoin swaps
The same deputies secured approval for a second amendment aimed at swaps into stablecoins. France currently taxes crypto gains when the holder sells for legal tender or pays for goods or services, and defers the tax on swaps between crypto-assets.
The amendment would rescind that deferral, from January 1, 2027, for swaps into stablecoins pegged to a single official currency, which the EU’s Markets in Crypto-Assets Regulation calls e-money tokens. Its explanatory note calls the present treatment a “hole in the legislation.”
Greece’s finance ministry, which published a draft 10% tax on crypto gains the same week, said swaps between crypto-assets would stay untaxed there.
Other crypto votes
The committee adopted an amendment from Daniel Labaronne, a deputy in President Emmanuel Macron’s Ensemble pour la République group, that would let holders carry realized crypto losses forward for ten years.
It also adopted one from centrist deputy Charles de Courson that would require that holders declare self-custody wallets to the tax administration when the assets in them are worth €100,000 (approximately US$112,000) or more on December 31. The explanatory note presents the declaration as an anti-fraud measure and cites a penalty of up to €10,000 (approximately US$11,200) for failing to file.
The committee rejected an Ecologist amendment that would have recast the real estate wealth tax as a tax on personal wealth, including crypto-assets.
Last year’s record
In October 2025, the same committee adopted an amendment that would have kept high earners liable for French tax for a decade after a move to a lower-tax country. The Assembly rejected it days later by a single vote, 132 to 131.
The Assembly voted on November 3, 2025, to reinstate the 15-year holding period that the exit tax carried before 2019, according to LCP.
But the change was not in the 2026 Finance Law, which the government pushed through under Article 49.3 of the Constitution, the provision that lets a bill pass without a vote unless deputies adopt a no-confidence motion.
