Crypto Law Profile

France BOFiP Digital Asset Capital Gains Guidance

BOFiP guidance explains France’s individual tax regime for occasional digital asset disposals under CGI art. 150 VH bis, covering scope, gain calculation, tax option, exemptions and reporting.

France Effective Tax guidance Jan 1, 2019

At a glance

Status BOFiP guidance is treated as in force; 2026 rate wording requires editor review.
Scope Targets natural persons making occasional disposals within private wealth management.
Gain Method Uses a portfolio formula based on sale price, total acquisition cost and portfolio value.
Reporting Form 2086 details disposals; totals flow to 2042-C boxes 3AN or 3BN.

Overview

France’s BOFiP Digital Asset Capital Gains Guidance is the official French tax-administration commentary on the capital-gains regime for individuals who dispose of digital assets on an occasional basis. The profile should be treated as an in-force French tax-guidance entry because BOFiP lists BOI-RPPM-PVBMC-30 as the current title for occasional digital-asset disposals and states that it covers scope, taxable base, taxation method and reporting obligations under Article 150 VH bis of the French General Tax Code.

The underlying statutory regime applies to covered disposals made from Jan. 1, 2019. BOFiP’s current overview was republished on Apr. 23, 2024, and the scope and taxable-base chapters remain shown as in force from Sept. 2, 2019. A 2026 editorial caveat is important: BOFiP’s rate section still presents the social-levy component as 17.2%, while the public impots.gouv.fr FAQ modified on Mar. 20, 2026 states a 31.4% PFU for private-wealth disposals, reflecting 12.8% income tax plus 18.6% social contributions.

What the BOFiP guidance covers

The BOFiP series is organized into three practical chapters. BOI-RPPM-PVBMC-30-10 addresses the scope of the regime, BOI-RPPM-PVBMC-30-20 explains the taxable base and gain calculation, and BOI-RPPM-PVBMC-30-30 covers taxation, forms and payment obligations. The guidance is aimed at occasional disposals by natural persons, directly or through an interposed entity, rather than business or professional trading activity.

Scope and taxable events

BOFiP treats taxable disposals as transfers for value of digital assets or related rights. The listed taxable consideration includes legal tender, a non-digital-asset good, an exchange with a cash adjustment, or a service. The guidance states that the private-wealth regime applies only to natural persons acting occasionally; habitual purchase-resale activity and certain mining-related gains are directed to business-income categories instead.

A key distinction is the treatment of crypto-to-crypto exchanges without a cash adjustment. BOFiP states that these exchanges benefit from a deferral and do not constitute a taxable event at that point. Conversely, an exchange with a cash adjustment is treated as taxable. The guidance also includes a small-disposal exemption where the total taxable disposal prices for the household do not exceed €305 during the tax year, excluding transactions benefiting from deferral.

Capital gain calculation and yearly netting

The taxable-base chapter uses a portfolio-based formula rather than a simple asset-by-asset cost-basis approach. BOFiP states that the gross gain or loss equals the sale price minus the product of the total acquisition price of the digital-asset portfolio and the ratio of the sale price to the global portfolio value. Amounts denominated outside the euro must be converted into euros at the exchange rate on the date of each transaction.

Annual netting is limited. Gross losses from digital-asset disposals may be offset only against gross gains of the same nature in the same tax year. A net annual loss cannot be carried forward and cannot be offset against gains from assets of another nature.

Rate, option and reporting

BOFiP’s 2024 rate section states that gains within Article 150 VH bis are taxed at 12.8% income tax and social levies, and that for disposals from Jan. 1, 2023 taxpayers may make an express, irrevocable global option for progressive income-tax treatment under Article 200 C. For current publication, editors should pair that BOFiP text with the 2026 impots.gouv.fr FAQ showing the current 31.4% PFU for private-wealth disposals.

Reporting is handled through the annual income-tax process. BOFiP says taxpayers report the annual net gain or loss on Form 2042-C and attach an administration-model annex detailing each taxable disposal or the prices of exempt disposals. The current impots FAQ identifies Form 2086 for online reporting and states that amounts flow to boxes 3AN or 3BN. It also flags Form 3916-3916bis for foreign digital-asset accounts.

Status and editorial treatment

As of July 6, 2026, this profile should remain categorized as in force, but with an editorial note that the statutory vocabulary now appears in Légifrance under “crypto-assets” from July 1, 2026 while BOFiP’s title still uses “actifs numériques.” The post should avoid advising taxpayers and should frame the guidance as an official interpretive source for France’s individual digital-asset capital-gains regime.

Key provisions

Private-wealth scope

Applies to individuals making occasional disposals of digital assets directly or through an interposed entity; professional activity is addressed outside this regime.

Taxation & Reporting Jan 1, 2019 Source

Taxable disposals and deferral

Covers disposals for fiat, non-digital goods, services or exchanges with cash adjustment; crypto-to-crypto exchanges without cash adjustment receive deferral treatment.

Payments Jan 1, 2019 Source

Small-disposal exemption

Households whose total taxable disposal prices do not exceed €305 in a tax year are exempt, excluding transactions that already benefit from deferral.

Taxation & Reporting Jan 1, 2019 Source

Portfolio-based gain formula

Gross gain or loss equals sale price minus total portfolio acquisition cost multiplied by sale price over global portfolio value, with euro conversion by transaction date.

Taxation & Reporting Jan 1, 2019 Source

Annual netting limits

Digital-asset losses may offset same-year gains of the same nature only; a net annual loss cannot be carried forward or offset against other asset gains.

Taxation & Reporting Jan 1, 2019 Source

Tax rate and progressive option

BOFiP states 12.8% income tax and a progressive-rate option from Jan. 1, 2023; current impots FAQ states a 31.4% PFU after social levies.

Taxation & Reporting Jan 1, 2023 Source

Annual reporting annex

Taxpayers report annual net gain or loss through the income-tax return and attach an administration-model annex listing taxable or exempt disposal data.

Taxation & Reporting Jun 28, 2019 Source

Foreign account reporting

French residents and certain entities must report digital-asset accounts opened, held, used or closed with foreign institutions under the related CGI regime.

Taxation & Reporting Jan 1, 2024 Source

Timeline

  1. Finance Law creates regime

    France’s 2019 finance law introduced the specific digital-asset disposal regime cited by BOFiP.

    Enacted Source
  2. Regime applies to disposals

    BOFiP states the regime applies to covered digital-asset disposals made from Jan. 1, 2019.

    In force Source
  3. Reporting decree adopted

    Decree 2019-656 specified reporting data for individual disposals and foreign digital-asset accounts.

    Enacted Source
  4. Initial BOFiP chapters published

    BOFiP published scope and taxable-base chapters for occasional digital-asset disposals.

    Enacted Source
  5. Progressive option applies

    Article 200 C option for progressive income-tax treatment applies to disposals made from this date.

    In force Source
  6. BOFiP updates rate chapter

    BOFiP updated BOI-RPPM-PVBMC-30 and 30-30 to reflect the Article 200 C progressive-rate option.

    Enacted Source
  7. Impots FAQ modified

    The public impots FAQ states 31.4% PFU for private-wealth disposals after 18.6% social levies.

    Enacted Source
  8. CGI wording enters 2026 version

    Légifrance shows Article 150 VH bis in force from this date under the heading “Crypto-actifs.”

    In force Source

Who it affects

Actors

BOFiP-Impôts, Direction générale des Finances publiques

Asset classes

Crypto assets, Digital assets

Official sources

Editorial note

BOFiP’s 2024 rate section refers to 17.2% social levies and a 30% total rate, while the impots.gouv.fr FAQ modified on Mar. 20, 2026 states 18.6% social levies and a 31.4% PFU. Editors should verify rate wording before publication. This is a legal-reference summary, not tax advice.