France's Finance Committee adopted the proposal on Oct. 7. It could tax swaps into certain MiCA e-money tokens from Jan. 1, 2027, while changing how older crypto holdings are assigned an acquisition cost. The National Assembly and the 2027 budget process still stand between the proposal and law.
The tax calculation would turn on the asset received, even if no euros reach a bank account. France's National Assembly Finance Committee adopted a proposal on Oct. 7 that would end tax deferral for exchanges into certain MiCA e-money tokens from Jan. 1, 2027, if enacted. The full National Assembly must still consider and vote on it as part of the 2027 budget process.
The change would bring forward the point when a gain is recognized. It would also change how acquisition costs are assigned, so the taxable gain on an initial swap could depend on the route chosen for assets acquired before 2027.
The proposal targets MiCA e-money tokens, which are crypto-assets referencing one official currency; it does not apply indiscriminately to every stablecoin.
Tax at the swap
Under current French tax authority guidance, many crypto-to-crypto exchanges without a cash balancing payment are tax-deferred. Converting crypto to fiat can already count as a taxable disposal under the private-disposal regime. So can using it to buy goods or services, subject to the applicable exemption.
Amendment I-CF1826 would remove that deferral when the asset received is an e-money token under the EU's Markets in Crypto-Assets regulation, or a related right. It would amend Article 150 VH bis of the French Tax Code, which governs private transactions in crypto-assets. Lawmaker Nicolas Sansu proposed the amendment and introduced it with 16 other members of the GDR group. MiCA defines an e-money token as a crypto-asset that aims to maintain stable value by reference to one official currency. The amendment focuses on what the investor receives; it does not expressly add an issuer-licensing condition. Its proposed calculation uses the difference between disposal value and acquisition cost, with a weighted-average acquisition price for tokens of the same nature. Cointelegraph's account also describes the measure's focus on e-money tokens.
Under the current French regime, exchanges between crypto-assets generally remain tax-deferred, while conversion to fiat or using crypto to pay for goods and services may be taxable. The proposal seeks to remove that difference for qualifying fiat-backed e-money tokens, even when the investor has not withdrawn funds to a bank account.
USDC is a concrete example. Circle's European white paper identifies it as an e-money token under the relevant MiCA provision. A swap from Bitcoin into qualifying USDC could therefore trigger recognition of a gain before a later conversion to euros or a bank withdrawal. The proposal concerns French tax treatment. It does not establish how the same transaction is treated for U.S. taxpayers.
The proposal's sponsors call the existing deferral for fiat-backed stablecoin exchanges a loophole. They argue investors can move into a currency-linked token and reduce market exposure without transferring funds to a bank. In practice, the change would tax a gain when an investor reduces market risk, rather than waiting for a cash-out. Separate EU stablecoin compliance measures covered in an earlier EU stablecoin report address provider restrictions. This proposal instead concerns when an investor's gain is recognized.
Two routes for old holdings
The amendment would also replace France's portfolio-wide acquisition-cost formula for taxable disposals. Under the current approach, part of the total portfolio acquisition price is allocated to a disposal. The calculation uses the ratio of the sale price to the portfolio's value just before the transaction. The proposed method would focus on the assets actually disposed of and use a weighted-average acquisition value for assets of the same nature bought at different prices.
For crypto acquired before 2027, holders could use evidenced actual acquisition costs under the new rules. Alternatively, they could allocate the portfolio acquisition price calculated under the old rules on Dec. 31, 2026, among the assets held then, in proportion to their values on that date. The choice would apply to the entire portfolio. It would become irrevocable when the holder files the first tax return reporting a taxable disposal after Jan. 1, 2027.
The difference is clear in a simple example. Suppose Bitcoin cost €20,000 and is worth €60,000 at the transition date. Ether cost €40,000 and is worth €40,000. Assume no prior disposals. The example also excludes fees, cash balancing payments and other holdings of those tokens. The old-rule portfolio acquisition-cost pool would be €60,000. The allocation route assigns €36,000 of basis to Bitcoin and €24,000 to Ether; the actual-cost route keeps their respective €20,000 and €40,000 costs.
If the Bitcoin is then swapped for €60,000 of native USDC, the proposed taxable gain would be €40,000 using actual cost or €24,000 using allocation. Under either route, the USDC would receive a €60,000 basis. If the remaining Ether is later sold for €40,000, the gain would be zero under actual cost or €16,000 under allocation. Across both disposals, each method recognizes €40,000 in gains. The timing and the asset on which the gain appears would differ.
A different purchase history can reverse which route produces the larger first gain. If Bitcoin had cost €50,000 and Ether €10,000, the Bitcoin swap would recognize a €10,000 gain under actual cost versus €24,000 under allocation. The later Ether disposal would then produce a €30,000 gain under actual cost or €16,000 under allocation. These figures assume unchanged euro values. They exclude fees and other transactions.
Basis and loss timing
The proposal distinguishes taxable exchanges from those that remain deferred. A deferred swap carries the surrendered asset's basis into the asset received. A taxable swap resets the received asset's basis to the consideration value used to calculate the gain, adjusted for any cash balancing payment. In the example, selling the USDC later for the same €60,000 would produce no further gain. A different euro value at disposal would require a separate calculation.
The loss rules would stay as they are. The tax authority says crypto gains and losses can offset within the same tax year, but a net crypto loss cannot be carried into a later year or used against gains on other assets. For example, Bitcoin bought for €30,000 and exchanged into €20,000 of native USDC would produce a €10,000 loss if the proposal applied. USDC would take a €20,000 basis. A later deferred exchange of that USDC into Bitcoin would carry the basis forward. Selling the Bitcoin for €30,000 would then create a €10,000 gain.
If the loss and gain fall in the same tax year, they could offset under the stated rule. If the loss comes first and the gain falls in a later year, the earlier loss would not shelter it. The sequence matters even if the holding ultimately returns to its original value.
Investors would need records supporting acquisition costs and weighted averages. They would also need to track basis changes through swaps. For older holdings, the allocation route requires a Dec. 31, 2026 valuation and locks the entire portfolio into one method.
The 2027 budget dossier, checked Oct. 12, lists National Assembly plenary discussion for Oct. 13. The committee vote is not enactment.
