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France's National Assembly just put a price on the parking lot. On 16 October 2026 it adopted amendment I-3898, a one-vote win that would treat a hop from bitcoin or ether into a MiCA e-money token as a taxable cash-out from 1 January 2027.
This France stablecoin tax story is not law yet. It is a first-reading floor amendment to the 2027 finance bill, and Stablecoin Insider walks through what I-3898 actually says, which tokens it hits, a worked tax example at the 31.4% flat rate, who it hurts, who it leaves alone, and what still has to clear the Senate.
Key Takeaways
- Scrutin n°8836 adopted I-3898 by 38-37 on 16 Oct 2026 (Assemblée nationale).
- It would tax crypto-to-MiCA EMT swaps from 1 Jan 2027 (amendment PDF).
- Flat tax at 31.4% on the gain, same as a fiat exit (Journal du Coin).
- Scope is MiCA e-money tokens, not every "stablecoin" (Reg. EU 2023/1114).
- Not law yet: solemn vote, Senate, Journal officiel still ahead (TokenPost).
What the Assembly adopted on 16 October 2026
Amendment I-3898 sits after article 4 of the 2027 finance bill. Nicolas Sansu (Gauche démocrate et républicaine) filed it on 10 October 2026 with sixteen co-signers, according to the official Assemblée nationale PDF. The Finance Committee had already nodded at the paired text on 7 October; the hemicycle took the public ballot on Friday afternoon.
The official analyse du scrutin n°8836 is thin and unambiguous: 100 voters, 75 expressed ballots, absolute majority at 38, 38 for, 37 against, 25 abstentions. The chair announced adoption. That is a one-vote floor win, not a landslide.
English and French desks landed the same headline within hours. TokenPost framed it as a 31.4% capital-gains proposal on qualifying crypto-to-stablecoin conversions that is not yet law. Blockchain Posts and Cryptoast stressed the MiCA e-money token filter and the 1 January 2027 start date. Up and Down hammered the point Stablecoin Insider agrees with: narrative is cheap; treating Friday's 38-37 as if the Journal officiel already printed it is early.
How article 150 VH bis works today
French private investors report crypto capital gains under article 150 VH bis of the code général des impôts. In the current design, an exchange of crypto-assets for other crypto-assets can sit in a sursis d'imposition, a deferral, until a later taxable event. Cash into legal tender, or spending crypto on goods and services, is the clean trigger.
Dollar- and euro-pegged tokens blurred that line years ago. Traders leave a volatile position, sit in a token that is supposed to hold a unit of currency, and wait. Sansu's explanatory note on the amendment PDF calls that a hole: a conversion into fiat-pegged stablecoins escapes the prélèvement forfaitaire unique (PFU) while a conversion into euro or dollar cash does not. The note also claims the United Kingdom and Italy have already moved that way. That UK/Italy line is the authors' claim in the filing, not a statute Stablecoin Insider verified for this piece.
For the broader map of how stablecoin exits and reporting land outside France, see Stablecoin Insider's stablecoin taxes guide.
What amendment I-3898 actually changes
The operative sentence is narrow. It adds a paragraph to the A of II of 150 VH bis: the exchange deferral does not apply when the seller receives electronic money tokens within the meaning of point 7 of paragraph 1 of article 3 of Regulation (EU) 2023/1114 of 31 May 2023, or rights relating to them.
MiCA's own definition is short. An electronic money token, or e-money token, is a crypto-asset that purports to maintain a stable value by referencing the value of one official currency, according to article 3(1)(7) of Reg. EU 2023/1114. Asset-referenced tokens are a different bucket. Algorithmic or crypto-collateralized dollars are not automatically EMTs because a trader treats them as cash.
That means the France stablecoin tax filter is a MiCA legal category, not a CoinMarketCap tag. Tokens commonly discussed as in-scope examples are authorised EMTs such as USDC and EURC. Tokens that are not EMTs under article 3(1)(7) sit outside this carve-out as written. Journal du Coin and Cryptoast both flag that asymmetry; Journal du Coin also relays market concern that volumes could shift toward non-EMT channels if the carve-out survives.
Sale price, cost basis and the 2027 transition
Once the exception fires, I-3898 rewrites how sale price and acquisition price are measured. Gross gain or loss equals sale price minus acquisition price of the crypto-assets disposed of. Sale price is the real price received or the value of the consideration obtained, reduced by documented disposal costs. Acquisition price is what was paid in legal tender (or the gift/inheritance value), plus documented acquisition costs, according to the amendment text.
Two reconstruction options matter for lots held before 1 January 2027. Taxpayers may either keep documented historical cost for each asset, or irrevocably allocate the 31 December 2026 portfolio acquisition total across holdings by their value on that date, when they first declare a post-2027 taxable disposal. Same-nature lots bought at different prices use a weighted-average cost. Cryptoast walked that weighted-average path with a two-lot bitcoin example in its 16 October report.
Section II.A of the amendment says the new rules apply to sales and exchanges from 1 January 2027. That is the date on the card. It is not a guarantee the Senate keeps it.
Worked tax example at the 31.4% flat rate
France's PFU flat tax on this class of private-investor crypto gains sits at 31.4%, according to Journal du Coin's coverage of I-3898 and TokenPost. The rate hits the gain, not the notional size of the swap.
Journal du Coin's own worked case is the cleanest published number to cite. A holder who moves €10,000 of bitcoin into a stablecoin with a €4,000 embedded gain would owe about €1,256 of tax on that hop (4,000 × 31.4%), without ever receiving euros in a bank account, per Journal du Coin.
Scale the same rate to a larger lot and the cash-flow shock is obvious. An illustrative case using that 31.4% rate: 1 BTC bought at €30,000 and converted into USDC when bitcoin prints €100,000 produces a €70,000 gain and about €21,980 of tax due at conversion. Blockchain Posts relays that figure as a Journal du Coin-style example of how the deferral disappears. Today that bill waits for a fiat exit. Under I-3898 as written, the EMT hop itself would start the clock.
| Scenario | Basis note | EMT proceeds | Gain | Tax at 31.4% |
|---|---|---|---|---|
| Journal du Coin published example | as reported by Journal du Coin | Journal du Coin: €10k notional | Journal du Coin: €4k gain | Journal du Coin: ≈ €1,256 |
| Blockchain Posts 1 BTC illustration | Blockchain Posts: €30k cost | Blockchain Posts: €100k | Blockchain Posts: €70k | Blockchain Posts: ≈ €21,980 |
Those figures are educational. They are not a personal tax computation. Cost basis, fees, prior deferrals and the final enacted text all move the number.
Who this France stablecoin tax would hurt
First of all, French tax residents who size risk in bitcoin, ether or other crypto, then rotate into MiCA EMTs as a risk-off sleeve, lose the free option. The parking lot stops being tax-deferred on 1 January 2027 if the article survives.
Venue desks that sell "stable" as the tax-free sideline have a product problem. So do issuers whose tokens are in the EMT bucket and whose French retail flow depends on that hop staying quiet. Treasury and ops teams that currently rebalance into USDC or EURC inside a French personal wrapper need a 2027 playbook, not a press release.
Here's why that matters for market structure. If only authorised EMTs trigger the tax and non-EMT pegs do not, rational flow can migrate toward the less regulated sleeve. That is exactly the asymmetry Journal du Coin flagged after the vote. Closing a deferral on the regulated token while leaving the unregulated parking lot open is a policy choice with predictable side effects.
Who it does not hit (yet)
- Anyone whose parking token is not an EMT under MiCA article 3(1)(7) (Reg. EU 2023/1114).
- Anyone already exiting to euro or dollar cash: that was already a PFU event under 150 VH bis.
- Non-residents outside the French 150 VH bis net.
- Anyone waiting for the Senate and the Journal officiel (TokenPost; Up and Down).
Of course, "not hit yet" is not the same as "safe forever." A later amendment can widen the filter. The current text is the one that won 38-37.
France vs MiCA, Japan and the rest of the EU
MiCA is a markets and issuer rulebook. It tells you what an EMT is, who may issue one, and how reserves and redemption work. It does not set French personal capital-gains rates. I-3898 borrows MiCA's EMT definition as a tax trigger and then applies France's own PFU. That is national tax law riding a European product label.
Japan is moving the other way on a related seam. Japan's FSA has pushed to keep trust-based yen stablecoins out of a tax rule built for family trusts, a relief path Stablecoin Insider covered in Japan's FSA trust stablecoin tax exemption. France is tightening the cash-like hop. Japan is trying not to punish the regulated yen token with a trust tax that was never meant for it. Same asset class, opposite instinct.
Across APAC the pattern is still jurisdiction-by-jurisdiction, which is why Stablecoin Insider's APAC stablecoin regulation map treats tax and licensing as separate layers. Inside Europe, euro-denominated issuer projects such as the EUROP euro stablecoin consortium care about MiCA authorisation first. French residents who later park gains in those EMTs would care about I-3898 second.
For a sense of how large the global parking lot is while this French fight runs, Stablecoin Insider's Q3 2026 stablecoin report tracks circulating supply and the concentration of dollar tokens. Size is not a MiCA licence list. It is the liquidity traders still treat as cash.
| Layer | What it decides | What I-3898 does with it |
|---|---|---|
| MiCA EMT definition | Which tokens are e-money tokens | Borrowed as the tax trigger |
| French 150 VH bis | When private crypto gains are taxed | Deferral removed for EMT receipts |
| PFU 31.4% | Rate on qualifying gains | Applied at the EMT hop from 2027 |
| Japan FSA trust angle | Keep yen trust tokens out of a family-trust tax | Opposite instinct: protect the regulated token |
The downside: a thin vote and a leaky perimeter
Let's start with the politics. A 38-37 adoption with 25 abstentions is not a settled coalition. Finance bills still face a solemn vote on the revenue block, a full Assembly text, Senate review, and possible use of article 49.3. Cryptoast and Journal du Coin both list those remaining gates. Any of them can rewrite or drop the carve-out.
Then comes the perimeter problem. Taxing only MiCA EMTs can push French retail flow toward pegs that are not EMTs. That undercuts the regulated issuers MiCA was supposed to privilege, and it leaves the original "parking lot" open for anyone willing to hold a non-EMT dollar token. Closing one deferral while leaving a substitute standing is how you get regulatory arbitrage inside a single wallet.
Traceability is the third crack. Even the minister for public accounts, speaking in the sitting, flagged how hard it is to follow reallocations inside a wallet, according to the floor account relayed by Up and Down. A rule that is crisp on paper and muddy in brokerage CSVs will produce both under-collection and over-penalties.
Stablecoin Insider's take
Stablecoin Insider would rather see EU capitals align the tax event with the economic cash-out and keep the regulated EMT sleeve from becoming the only punished parking lot. Punishing the MiCA-compliant token while sparing the non-EMT substitute is backwards industrial policy.
What to watch next
- Whether I-3898's article remains in the adopted first-reading revenue text, not only on the Adopté amendment card.
- The solemn vote on the first part of PLF 2027 (Journal du Coin calendar pointed to 20 October 2026).
- Senate text: restore full 150 VH bis deferral for EMT receipts, keep the carve-out, or widen it.
- Parallel measures still in the same fiscal basket: wallet reporting from €100,000 and an exit-tax idea above €800,000 (TokenPost; Journal du Coin).
Need the wider map of how stablecoin gains, swaps and reporting work outside France? Stablecoin Insider's tax guide is the operator checklist.
FAQ
What is the France stablecoin tax amendment I-3898?
It is a first-reading amendment to France's 2027 finance bill that would remove the tax deferral on crypto-to-MiCA e-money token swaps from 1 January 2027. The Assembly adopted it 38-37 on 16 October 2026 per the official scrutin n°8836.
Is the France stablecoin tax law yet?
No. It still needs to survive the rest of the finance bill path, including Senate review and publication in the Journal officiel. TokenPost and Up and Down both stress that Friday's vote is not a live tax.
Which stablecoins would the France stablecoin tax cover?
Only receipts of MiCA electronic money tokens under article 3(1)(7) of Reg. EU 2023/1114, or rights tied to them. That is a legal category, not every token traders call a stablecoin.
What tax rate would apply?
The French PFU flat tax of 31.4% on the capital gain, the same rate used for a fiat exit, according to Journal du Coin and TokenPost.
When would amendment I-3898 start?
The amendment text says sales and exchanges from 1 January 2027, per the Assemblée PDF. That date only bites if the final statute keeps it.
Does converting crypto to euros already trigger tax in France?
Yes. A fiat exit was already a taxable event under article 150 VH bis. I-3898's point is to treat a hop into a MiCA EMT like that cash-out. See Stablecoin Insider's stablecoin taxes guide for the wider picture.
What happens to cost basis for tokens bought before 2027?
The amendment offers two options: keep documented historical cost per asset, or irrevocably allocate the 31 December 2026 portfolio cost by value on that date when you first declare a post-2027 taxable disposal (amendment PDF).
How does this compare with Japan's stablecoin tax debate?
Japan's FSA has argued for keeping trust-based yen stablecoins out of a family-trust tax rule. France is tightening the cash-like hop. Opposite instincts on the regulated token; details in Stablecoin Insider's Japan FSA piece.
Forward look: the next print that matters is not another headline about Friday's 38-37. It is whether the EMT carve-out is still in the text the Assembly transmits, and whether the Senate keeps it. Until the Journal officiel speaks, the France stablecoin tax is a planning assumption with a date stamp of 1 January 2027, not a collection notice.
This content is provided for informational and educational purposes only and does not constitute financial, investment, legal, or tax advice; it is not financial advice, and no material herein should be interpreted as a recommendation, endorsement, or solicitation to buy or sell any asset or token. French finance bills change in the Senate and in final votes; nothing here is a filing instruction or a solicitation to restructure a portfolio. Confirm every rule with a licensed French tax adviser before you act. Nothing here is a solicitation to buy or sell.
