France’s National Assembly finance committee adopted an amendment to the 2027 budget bill on 8 October 2026 that would extend the country’s exit tax to crypto-assets held by taxpayers transferring their tax residence abroad. The proposal would apply to households holding crypto-assets worth more than €800,000, with the measure intended to cover departures from 1 January 2027. However, the amendment has not yet been approved by the full National Assembly and is not currently law. The proposal comes amid broader debates over France’s public finances and measures to increase government revenue.
Proposed Extension of the Exit Tax to Crypto-Assets
The amendment, introduced by Communist deputy Nicolas Sansu and 16 colleagues from the Gauche démocrate et républicaine group, would add a new Article 167 ter to France’s General Tax Code. It would apply to taxpayers who had been French tax residents for at least six of the ten years preceding their departure and whose households held crypto-assets exceeding €800,000 in total value. The tax would be calculated on unrealized gains, based on the market value of the assets at departure minus their total acquisition cost.
The proposal covers crypto-assets held directly, through service providers, or via third parties, including foreign accounts and self-custody wallets. Departing taxpayers would be required to declare their crypto holdings. Individuals who had been French tax residents for fewer than six of the preceding ten years would fall outside the proposed measure, consistent with the existing residence requirement under the exit tax framework.
Existing Exit Tax Rules and Proposed Tax Treatment
France’s existing exit tax applies to departing taxpayers who hold securities worth more than €800,000 or own at least 50% of the rights to a company’s profits. Under the proposed amendment, similar calculation and deferral rules would be extended to qualifying crypto portfolios. However, the amendment does not specify a tax rate or clarify whether social security charges would apply to crypto-related gains.
Tax Deferral and Relief for Departing Taxpayers
Under the existing framework, payment of the exit tax is automatically deferred for taxpayers moving to another EU Member State or to certain countries that have agreements with France covering administrative assistance and tax recovery. For departures to other countries, taxpayers must request deferral before leaving, appoint a tax representative in France, and provide a guarantee equal to 12.8% of the relevant gains.
The tax liability can be extinguished if the taxpayer continues to hold the relevant assets until the applicable holding period expires. This period is generally two years after departure, extending to five years for portfolios exceeding €2.57 million. The proposed amendment would extend similar rules to crypto-assets, with adjustments for crypto-specific transactions.
Crypto-to-Crypto Swaps and Stablecoin Transactions
The amendment would treat swaps between crypto-assets differently from conventional disposals. Exchanges of one crypto-asset for another without cash changing hands would not count as sales under the proposed exit tax rules. If a taxpayer sold part of a portfolio before the relevant holding period expired, a proportionate share of the tax would become payable.
Separately, the finance committee adopted another amendment that would remove the current tax deferral for swaps into stablecoins pegged to a single official currency, known under the EU’s Markets in Crypto-Assets Regulation as e-money tokens. If enacted, the change would take effect on 1 January 2027. The proposal’s authors argue that the existing treatment creates a gap in the legislation by allowing certain transactions to defer taxation.
Legislative Process and Budgetary Context
The proposed crypto exit tax forms part of France’s 2027 budget debate, as the government seeks approximately €54 billion in savings and additional revenue to reduce the budget deficit to 5% of GDP in 2027. The committee’s adoption of the amendment does not guarantee its approval by the full Assembly. Under Article 42 of the French Constitution, the full chamber must debate the finance bill in the form submitted by the government, meaning committee amendments must be considered again during the plenary process.
The finance committee rejected the revenue portion of the budget bill as a whole on 9 October 2026. Floor debates began on 13 October, with a vote on the revenue section scheduled for 20 October. Neither the crypto exit tax amendment nor the separate stablecoin amendment was included in the government’s original budget bill submitted on 1 October.
Previous Attempts to Expand France’s Exit Tax
The latest proposal follows earlier attempts to increase the tax burden on individuals leaving France. In October 2025, the finance committee adopted an amendment that would have kept certain high earners liable for French tax for ten years after moving to a lower-tax jurisdiction. The National Assembly subsequently rejected that proposal by a single vote.
The Assembly also voted in November 2025 to reinstate a 15-year holding period under the exit tax rules, but that change was not included in the 2026 Finance Law. These previous developments illustrate that committee approval alone does not ensure that a tax proposal will become part of the final legislation.
Summary
France’s proposed extension of the exit tax to crypto-assets could have significant implications for wealthy crypto holders considering a change of tax residence. If enacted, the measure would subject qualifying unrealized crypto gains to rules similar to those already applied to certain securities, while introducing specific provisions for crypto swaps, tax deferral, and partial disposals. The proposal remains subject to parliamentary approval, and its final scope, tax treatment, and implementation will depend on the outcome of the legislative process.
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