France has no immunity door and no programme: the dedicated desk for foreign holdings closed in 2017, and nothing replaced it. What exists is a ladder of surcharges — 10% for simple lateness, 40% for deliberate failure or for not filing after a formal notice, 80% for fraudulent schemes or hidden activity — plus late interest at 0.20% a month. Spontaneity does not erase the bill: it keeps you at the bottom of the ladder, out of the punitive rates, out of assessment by default — and out of the criminal track, whose referral to the prosecutor became automatic above €100,000 of evaded tax carrying a surcharge of 40% or more.
The route, concretely
The move is prosaic: corrective returns for each open year — the 2042 with its 2086 and 3916-bis annexes — filed from your personal space under "Corriger ma déclaration", with an express note stating the spontaneous initiative, and payment of tax and interest. The note is not a courtesy: it dates your initiative, and that date is what separates you from the taxpayer who was caught. The fixed fines for omitted forms are negotiable — documented good faith and the absence of hidden income genuinely weigh in the reduction.
Vienna forgives the sequence, Bern forgives once, Berlin demands the decade, Madrid bills by tariff. Paris neither forgives nor bills: it grades — and you pick your rung of the ladder by the date of your filing.
What a crypto regularisation assembles
The usual pieces: euro disposals never carried onto a 2086 — often because "everything stayed in crypto" except a few forgotten exits; missing 3916-bis forms holding the assessment window open to ten years; staking rewards whose classification was never chosen; and the global cost basis to rebuild from the origin — because every corrective return is computed with the formula, not with an exported FIFO. Reconstruction precedes decision: the real number surprises, in both directions.
The sequence
- Reconstruct before deciding. Every open year, the full acquisition history, the portfolio value at each disposal — the number first, the choice after.
- File complete, in one move. 2086, 3916-bis and 2042 coherent with each other, with the express note — piecemeal corrections invite review of the whole.
- Pay tax and interest with the filing. A spontaneous initiative is judged by its execution — commitment without payment is not one.
- At heavy amounts, counsel before any filing. The automatic-referral thresholds can be computed — and plead badly after the fact.
- If a letter already arrived, change playbooks. Formal notice or rectification: the spontaneous window is closing — from here you manage a proceeding, with representation.
Surcharges, interest and thresholds depend on facts and dates this page does not know. It frames the decision; it does not make it, and reading it creates no professional relationship.