French MPs propose bringing crypto gains into the exit tax

French MPs have tabled 2027 budget amendments that would bring crypto-assets into France’s exit tax. Adopted by the National Assembly’s finance committee on 8 October, a day before it rejected the bill’s revenue part, the measure was re-tabled in two versions on 10 October. It would tax unrealised crypto gains when a household holding over €800,000, in crypto alone or with securities, leaves after at least six of ten years’ French tax residence. None of it is law.

For a Vietnamese family, the rule would apply only to a household that was French tax-resident for at least six of the ten years before the move and held crypto above the threshold, for example a family that settled in France on the investor residence card, became tax-resident there and later moves on. The departure return would have to list all crypto held on the day of the move, including holdings on accounts or wallets opened abroad or kept in self-custody; on TLT’s reading, an account with a provider licensed under Vietnam’s crypto pilot would count as an account opened abroad. Vietnam is not on the tax authority’s current list, for moves from 2025, of destinations for which France defers its exit tax automatically.

What the committee adopted

The amendment, I-CF1822, was tabled on 4 October by Nicolas Sansu of the Gauche démocrate et républicaine (GDR) group and 16 other MPs. In TLT’s translation, the new Article 167 ter of the General Tax Code would open: “Taxpayers who were tax-domiciled in France for at least six of the ten years preceding the transfer of their tax domicile outside France are taxable, on that transfer, on the unrealised gains recorded on crypto-assets [as defined in paragraph I of Article 150 VH bis] and on rights relating to them.”

The charge would cover crypto held on the day of departure by members of the tax household, directly or through a crypto-asset service provider “or any other third party”, where the total value exceeds €800,000. The rule would apply to departures, meaning transfers of tax domicile out of France, from 1 January 2027.

The amendment states no rate of its own: the tax is computed under paragraph II bis of Article 167 bis, the existing exit tax, and the authors’ explanatory note says it reuses that mechanism, rate included. The deferral, cancellation and reporting rules of Article 167 bis would also apply, with adaptations for crypto.

Two versions before the full Assembly

I-3432, filed on 10 October by Mickaël Bouloux and the Socialist group, repeats the committee’s Article 167 ter. I-3904, filed the same day by Sansu’s group, instead treats crypto-assets as securities within Article 167 bis and applies the €800,000 threshold to securities and crypto combined. On TLT’s reading, under I-3904 a household with less than €800,000 in crypto could still be caught if its securities and crypto together exceed €800,000. Which version, if either, the Assembly adopts is open.

How the exit tax works now

According to the tax authority’s 2026 filing notice, which calls itself indicative, the exit tax applies after six of the ten years before the move to people holding at least 50% of a company’s profits, or securities worth more than €800,000 on departure. The default charge is 12.8% income tax plus social charges of 18.6% for 2026 departures.

Payment is deferred automatically for a move to another EU state or to a listed state with administrative and recovery assistance agreements with France. The list for moves from 2025 includes the United States, the United Kingdom, Japan, South Korea and Australia; Vietnam is not on it. Elsewhere the tax is in principle due at once, unless the taxpayer asks for deferral, which requires a tax representative in France and guarantees. The tax is cancelled or refunded if the holdings are still held two years after the move, or five years where they exceeded €2.57m at departure. On TLT’s reading, because the committee text imports these rules, a family leaving France for Vietnam with crypto above the threshold would face the same choice: pay at once, or ask for deferral with a representative and guarantees. Whether crypto gains would also bear the social charges is not established.

Self-custody wallets and stablecoins

A second amendment, I-CF821 from Charles de Courson of the LIOT group, adopted on 9 October, would require taxpayers to declare crypto wallets they hold directly, outside any crypto-asset service provider, where the wallets hold €100,000 or more on 31 December. Today the duty described by BOFiP, the tax authority’s official doctrine, covers digital-asset accounts opened with entities established abroad, at a fine of €750 per undeclared account, or €1,500 where such accounts exceed €50,000; on TLT’s reading, no duty covers self-custody wallets. The amendment’s penalty works by cross-reference to Article 1729 C ter, and the text states no amount. It was re-tabled as I-2701.

A third amendment, I-CF1826 from Sansu, adopted on 7 October, would end the exemption for swaps in which the seller receives e-money tokens as defined in the EU’s MiCA regulation, which the authors call stablecoins. Swaps between digital assets without a cash adjustment are not taxable today; on TLT’s reading, swaps into such tokens would become taxable from 1 January 2027. It was re-tabled as I-3898 and I-3680.

Where the bill stands

On the evening of 9 October the finance committee rejected the revenue part of the bill by 31 votes to 3, with 2 abstentions, according to LCP, the National Assembly’s parliamentary channel; the committee’s minutes and report had not been published by 13 October. Under Article 42 of the Constitution, the plenary debates the Government’s text at first reading of a finance bill, and the Assembly’s guide says the committee adopts only amendments, not a text. Committee amendments to a finance bill therefore do not carry over to the plenary; their authors re-tabled them on 10 October.

The plenary debate on the revenue part runs from 13 to 19 October, with a vote on that part on 20 October and on the whole bill on 17 November, according to the Assembly’s timetable, before the Senate takes it up. The same document puts the end of Parliament’s 70-day period at midnight on 17 December, counted from 9 October rather than from the bill’s tabling on 1 October; under Article 47, if Parliament has not decided by then, the bill can be brought into force by ordinance.

No Government statement on the amendments was found; the plenary debate had not started when TLT checked on the morning of 13 October, Paris time.

What this article has not established

TLT has not read the statutory texts of the current exit tax and declaration rules directly; current-law points rest on the tax authority’s notice and on BOFiP. It has not established the fine for an undeclared self-custody wallet, whether crypto gains would bear social charges, the official vote count of 9 October, the Senate’s calendar, which exit-tax version survives, or the Government’s position. The deferral list for 2027 departures and the France–Vietnam tax treaty were not checked.