Key Takeaways
- • France's National Assembly Finance Committee adopted amendment I-CF1826 on Oct. 7, 2026, making a swap of Bitcoin or Ether into MiCA-defined e-money tokens such as USDC a taxable disposal even if the investor never withdraws cash.
- • If enacted, the provision would apply to disposals and exchanges from Jan. 1, 2027, removing the existing tax deferral on covered crypto-to-crypto exchanges where the received asset is an e-money token.
- • The proposal replaces the portfolio-wide acquisition-cost formula with asset-specific weighted-average basis, and gives pre-2027 holdings a one-time choice between evidenced actual costs and an allocation of the Dec. 31, 2026 portfolio cost pool, which becomes irrevocable once elected.
- • Under the proposed reset rules, USDC received in a taxable swap takes a basis equal to the consideration value, which prevents double recognition of the same gain on later cash-out at unchanged euro value.
- • Crypto losses would still offset gains only within the same tax year, and net losses cannot be carried forward or applied to other asset gains.
Summary
France's National Assembly Finance Committee adopted amendment I-CF1826 on October 7, 2026, as part of a broader overhaul of how private crypto gains are calculated within the 2027 budget dossier. The amendment would treat a move from Bitcoin or Ether into certain stablecoins as a taxable disposal, even if the investor never withdraws cash. According to the source reporting, the provision would apply from January 1, 2027 if enacted. The 2027 budget dossier, checked October 12, lists National Assembly plenary discussion for October 13. Publisher coverage notes that neither proposal is final.
Under current French tax authority guidance, covered crypto-to-crypto exchanges without a cash balancing payment receive tax deferral, and conversion into fiat remains taxable under the private-disposal regime. CF1826 would remove that deferral where the investor receives e-money tokens as defined under the EU's Markets in Crypto-Assets (MiCA) regulation, or related rights. Circle's European white paper identifies USDC as an e-money token under the same MiCA provision, so a Bitcoin-to-USDC swap would recognize gain before any later cash withdrawal. The amendment's sponsors describe deferral on fiat-backed stablecoin conversions as a legislative loophole. The amendment invokes the MiCA definition without an express issuer-licensing condition.
The proposal changes how basis is calculated. France's existing method allocates the acquisition price of the entire crypto portfolio to each disposal. The replacement would focus on the assets actually disposed of, using weighted-average acquisition value for assets of the same nature bought at different prices. For holdings acquired before 2027, investors could use evidenced actual acquisition costs, or allocate the portfolio acquisition price calculated under the old rules at December 31, 2026 among holdings in proportion to their values on that date. The allocation election is irrevocable for the entire portfolio when the first return reporting a taxable disposal after January 1, 2027 is filed.
The source illustrates the mechanics with a hypothetical investor holding Bitcoin costing €20,000 (worth €60,000) and Ether costing €40,000 (worth €40,000). Under the allocation route, Bitcoin receives €36,000 of basis versus €20,000 under actual cost, so the same €60,000 USDC swap yields a €24,000 gain rather than €40,000. The reset rule gives the received USDC a €60,000 basis, so later sale at the same euro value produces no further gain. The publisher notes that USDC references the dollar, so later disposals at different euro values would require their own calculation. The examples are gross hypotheticals and assume no fees or cash balancing payments.
Loss treatment is unchanged under the amendment. Crypto gains and losses offset within the same tax year, and a net crypto loss cannot be carried into later years or set against gains on other assets. Asset-specific basis would simplify the calculation for new disposals but would require investors to retain acquisition evidence, weighted averages and carried basis through swaps.
Under current French tax authority guidance, covered crypto-to-crypto exchanges without a cash balancing payment receive tax deferral, and conversion into fiat remains taxable under the private-disposal regime. CF1826 would remove that deferral where the investor receives e-money tokens as defined under the EU's Markets in Crypto-Assets (MiCA) regulation, or related rights. Circle's European white paper identifies USDC as an e-money token under the same MiCA provision, so a Bitcoin-to-USDC swap would recognize gain before any later cash withdrawal. The amendment's sponsors describe deferral on fiat-backed stablecoin conversions as a legislative loophole. The amendment invokes the MiCA definition without an express issuer-licensing condition.
The proposal changes how basis is calculated. France's existing method allocates the acquisition price of the entire crypto portfolio to each disposal. The replacement would focus on the assets actually disposed of, using weighted-average acquisition value for assets of the same nature bought at different prices. For holdings acquired before 2027, investors could use evidenced actual acquisition costs, or allocate the portfolio acquisition price calculated under the old rules at December 31, 2026 among holdings in proportion to their values on that date. The allocation election is irrevocable for the entire portfolio when the first return reporting a taxable disposal after January 1, 2027 is filed.
The source illustrates the mechanics with a hypothetical investor holding Bitcoin costing €20,000 (worth €60,000) and Ether costing €40,000 (worth €40,000). Under the allocation route, Bitcoin receives €36,000 of basis versus €20,000 under actual cost, so the same €60,000 USDC swap yields a €24,000 gain rather than €40,000. The reset rule gives the received USDC a €60,000 basis, so later sale at the same euro value produces no further gain. The publisher notes that USDC references the dollar, so later disposals at different euro values would require their own calculation. The examples are gross hypotheticals and assume no fees or cash balancing payments.
Loss treatment is unchanged under the amendment. Crypto gains and losses offset within the same tax year, and a net crypto loss cannot be carried into later years or set against gains on other assets. Asset-specific basis would simplify the calculation for new disposals but would require investors to retain acquisition evidence, weighted averages and carried basis through swaps.
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