A French National Assembly finance committee vote has put large crypto portfolios inside a proposed version of the country’s exit-tax regime. Amendment I-CF1822 was adopted in committee on October 8, 2026, but the measure is still part of a bill at first reading. It should be read as a legislative proposal, not as a tax rule already in force.
Who would fall within the proposal
The amendment would create a new Article 167 ter in France’s General Tax Code. It covers a taxpayer who had been resident in France for at least six of the ten years before moving their tax residence abroad. The portfolio test applies when the household’s crypto-assets and related rights have a total value above €800,000 at departure.
The wording is designed to reach more than exchange accounts. It includes assets held directly, through a crypto-asset service provider or through another third party. A separate reporting provision would require a departing taxpayer to list assets held in foreign accounts and self-custodied wallets. That makes recordkeeping relevant even where no custodian can prepare a complete statement.
How the unrealized gain would be measured
Under the proposal, the latent gain would be the difference between the portfolio’s total value on the departure date and its total acquisition cost. Valuation methods would be set by decree. If no reference price exists, the amendment says market value would be used.
The draft does not give symmetrical treatment to an unrealized loss. Such a loss could not be offset against latent gains covered by the existing exit-tax article or carried forward. For taxpayers holding many assets acquired at different times, that distinction would make a reliable cost-basis history as important as the departure-date valuation.
Portfolio rules matter after departure
The amendment adapts existing exit-tax mechanics rather than treating each token transfer as an immediate disposal. A crypto-to-crypto exchange without a cash adjustment would not count as a sale for this purpose. If part of the portfolio were sold before the applicable holding period expired, the tax would become payable in proportion to the part sold, measured against the portfolio’s value when the taxpayer left France.
The proposal also points to existing rules for payment deferral, relief, declarations, enforcement and collection, subject to its crypto-specific changes. Those cross-references matter: the headline threshold alone does not show when payment would be deferred or later relieved.
What holders should watch
The official record says the measure would apply to transfers of tax residence from January 1, 2027. That date is conditional on the text surviving the remaining legislative process. Committee adoption establishes what lawmakers approved at that stage; it does not establish final enactment.
For potentially affected holders, the practical preparation is evidence rather than relocation planning: preserve acquisition records, identify which wallets belong to the tax household, document custody arrangements and retain a defensible valuation method. Final obligations could change before passage, and individual treatment would still depend on the enacted text and its implementing decree.
Source: BlockchainReporter.