France’s tax proposal would tax Bitcoin-to-USDC swaps before investors cash out

France’s proposed crypto tax changes would make a move from Bitcoin or Ether into certain stablecoins a taxable disposal, even if the investor never withdraws cash.

The National Assembly’s Finance Committee adopted amendment I-CF1826 on Oct. 7, adding that proposed exception to a broader overhaul of how private crypto gains are calculated. The provision would apply to disposals and exchanges from Jan. 1, 2027 if enacted.

For an investor selling Bitcoin exposure into USDC, the consequence would be a change in the tax timing of a risk-reduction trade. A gain could become reportable while the proceeds remain in a crypto wallet or exchange account. But the proposal also changes the cost deducted from those proceeds, and gives older holdings a transition choice.

Under French tax authority guidance, covered crypto-to-crypto exchanges without a cash balancing payment receive tax deferral. Converting into fiat or using crypto to obtain other goods or services can already be taxable under the private-disposal regime, subject to its applicable exemption.

CF1826 would remove the exchange deferral when the investor receives e-money tokens as defined by the EU’s Markets in Crypto-Assets regulation, or related rights. The operative wording targets the asset received. A swap out of Bitcoin into a qualifying token could therefore recognize a gain before any later cash withdrawal.

MiCA’s definition describes a crypto-asset that seeks to maintain stable value by reference to one official currency. That legal definition sets the exception’s scope. The amendment invokes it without an express issuer-licensing condition.

USDC provides a concrete example: Circle’s European white paper identifies it as an e-money token under the same MiCA provision. The illustrations below use native USDC, with transactions measured in euros.

The amendment’s sponsors justify the change by describing deferral on fiat-backed stablecoin conversions as a legislative loophole. For an investor using a swap to reduce market exposure, the practical effect would be earlier recognition of any gain.

The proposed tax calculation concerns the gain above cost. It subtracts the acquisition basis of the assets surrendered from the disposal price. That basis is the cost recognized for tax purposes; a transaction can produce a gain, no gain or a loss.

France’s existing portfolio-based calculation allocates part of the acquisition price of the entire crypto portfolio to each taxable disposal. Current guidance deducts total portfolio acquisition price multiplied by the ratio of disposal price to portfolio value immediately before the transaction.

The proposed replacement would focus on the crypto-assets actually disposed of. For assets of the same nature purchased at different prices, it specifies weighted-average acquisition value.

For holdings acquired before 2027, the amendment offers two routes. An investor could use evidenced actual acquisition costs, determined under the new basis rules. Alternatively, the investor could allocate the portfolio acquisition price calculated under the old rules at Dec. 31, 2026 among the assets held then, in proportion to their values on that date.

The allocation option preserves a pool of acquisition cost and distributes it among holdings. The available cost pool remains the acquisition price calculated under the old rules, rather than the portfolio’s full market value. The text makes that choice irrevocable for the entire portfolio when the first return reporting a taxable disposal after Jan. 1, 2027 is filed.

Consider a hypothetical investor whose Bitcoin cost €20,000 and is worth €60,000, while their Ether cost €40,000 and is worth €40,000 at the transition date. The portfolio has €60,000 of acquisition cost and a €100,000 value. Assume no prior disposals, fees or cash balancing payments, no other holdings of the same tokens, and unchanged euro values through the transactions.

Under the allocation option, Bitcoin represents 60% of the portfolio value and receives €36,000 of basis. Ether receives the remaining €24,000. Using actual costs instead would leave their bases at €20,000 and €40,000, respectively.

The same Bitcoin-to-USDC transaction would then produce different first-disposal gains: