France is considering a change that could bring some crypto-to-crypto swaps into the tax system before investors convert their holdings into euros or withdraw money from an exchange.
According to CryptoSlate, the National Assembly’s Finance Committee approved amendment I-CF1826 on Oct. 7. If it becomes law, the measure would apply to disposals and exchanges carried out from Jan. 1, 2027. It would end the current tax deferral for certain transactions in which an investor exchanges crypto for a qualifying electronic-money token under the European Union’s Markets in Crypto-Assets regulation, or MiCA.
The practical example is a Bitcoin or Ether holder swapping into USDC. Under the proposal, that transaction could itself be treated as a taxable disposal, even if the USDC remains in a wallet or on a trading platform and is never exchanged for cash.
What the proposed rule would change
French tax guidance currently allows tax deferral for covered crypto-to-crypto exchanges when there is no cash balancing payment. Tax can already arise when crypto is converted into fiat currency or used to buy goods and services, subject to the rules and exemptions applicable to private disposals.
Amendment I-CF1826 would create an exception based on the asset received. A swap into an e-money token covered by MiCA would no longer automatically receive that deferral. MiCA defines the relevant category as a crypto-asset intended to maintain a stable value by referring to one official currency.
USDC is used as the central example because Circle’s European white paper identifies the token as an e-money token under the relevant MiCA provision. The amendment refers to the legal category without expressly adding an issuer-licensing condition.
For tax purposes, the gain or loss would be calculated by comparing the value of the asset disposed of with its acquisition basis. The basis is the cost recognized for tax purposes. Consequently, a Bitcoin-to-USDC swap could produce a taxable gain while the investor’s economic position remains entirely within crypto assets.
The amendment’s sponsors describe the existing deferral for conversions into fiat-backed stablecoins as a loophole. The proposed treatment would therefore bring forward the point at which a gain is recognized for a trade that may simply be intended to reduce exposure to Bitcoin or another volatile asset.
Transition rules for crypto bought before 2027
The proposal would also replace the current portfolio-based approach with rules focused on the assets actually disposed of. For assets of the same type acquired at different prices, the calculation would use a weighted-average acquisition value.
Investors holding crypto before 2027 would have two possible ways to determine basis:
- They could use documented acquisition costs under the new asset-specific rules.
- They could allocate the portfolio acquisition cost calculated under the existing rules at Dec. 31, 2026 among the assets held on that date, according to their respective values.
The second choice would preserve a pool of historical acquisition cost rather than assigning the portfolio’s full market value as cost. The decision would be irrevocable for the entire portfolio once the first tax return reporting a taxable disposal after Jan. 1, 2027 is filed.
The choice could affect how much gain is reported on the first disposal. In one illustration, Bitcoin had originally cost €20,000 and was worth €60,000 at the transition date, while Ether had cost €40,000 and was worth €40,000. The total historical cost was €60,000, against a portfolio value of €100,000.
Under the allocation route, Bitcoin would receive €36,000 of basis and Ether €24,000. Using actual costs would instead leave the assets with bases of €20,000 and €40,000. A later Bitcoin-to-USDC swap at €60,000 would therefore produce different first-disposal gains depending on the selected method.
The result can reverse when the historical costs change. The source’s second illustration gives Bitcoin a €50,000 cost and Ether a €10,000 cost. In that case, actual cost would create a €10,000 Bitcoin gain, while the allocation method would produce a €24,000 gain. The method producing the larger initial gain depends on the investor’s historical purchase prices.
New basis for received tokens and loss timing
The proposal distinguishes between exchanges that remain tax-deferred and those treated as taxable. In a deferred exchange, the received assets inherit the basis of the assets surrendered. In a taxable exchange, the received assets would generally receive a basis tied to the consideration used to calculate the gain, adjusted for any cash balancing payment.
In the first illustration, the USDC received for Bitcoin would have a €60,000 basis under either transition method. If its euro value remained €60,000 when it was later sold, that later transaction would create no additional gain. A change in its euro value would require a separate calculation.
The proposed change would not remove France’s existing restriction on crypto losses. Gains and losses can offset within the same tax year, but a net crypto loss cannot be carried into a later year or used to offset gains from other assets.
For example, a Bitcoin holding bought for €30,000 and exchanged for €20,000 of USDC would produce a €10,000 loss, with the USDC receiving a €20,000 basis. If that USDC were later exchanged into Bitcoin in a transaction that remained deferred, the €20,000 basis would carry into the Bitcoin. A subsequent taxable sale for €30,000 would create a €10,000 gain.
If the loss and gain occurred in the same tax year, they could offset. If they occurred in different years, the earlier loss could not shelter the later gain under the existing rule. The timing of recognition could therefore affect the tax result even where the sequence eventually returns the holding to its original value.
Market picture
Moneyiar data at 10:09 a.m. on Oct. 13, 2026, put Bitcoin at $83,508.353571493, up 0.12% over 24 hours but down 2.9% over seven days. USDC was $0.9997621847 at 10:08 a.m., down 0.01% over both periods.
The same Moneyiar snapshot showed Monad at $0.0246368197, down 4.72% in 24 hours and 13.12% over seven days. Ethereum Name Service was $5.9820625884, down 4.93% over 24 hours and 12.91% over seven days.
The legislative process is not complete. The 2027 budget dossier listed National Assembly plenary discussion for Oct. 13, meaning the proposal still faced further parliamentary consideration before it could take effect.
