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HolderTax / France / Rules / Crypto-to-crypto
Rule explainer · France · Schedule lines 04–05

The crypto-to-crypto swap: taxation deferred

Swapping Bitcoin for Ether triggers no tax in France. This deferral — rare anywhere — is not a favour: it is a postponement. Everything your swaps accumulate waits for the exit into euros, and arrives that day all at once.

Working draft · mechanics pending sign-off by a licensed reviewer · not advice on your operations

What the deferral covers

Exchanges between digital assets without a cash sweetener enjoy a tax deferral — a principle consolidated by the finance act for 2024. BTC for ETH, ETH for a stablecoin, one stablecoin for another token: none of these is a taxable event. You can arbitrage, rotate and rebalance without triggering a computation or a filing — where Berlin, Madrid and Washington would tax every rotation. It is the most distinctive mechanic in French crypto taxation, and the most misunderstood in both directions.

What breaks it

Three moves bring the tax back: disposal against legal tender — euros, dollars, including selling a stablecoin for euros; buying a good or service paid in crypto — the car settled in BTC is a taxable disposal; and a swap with a soulte — a cash balancing payment — taxable up to that amount. The classic trap: believing that "staying in stablecoins" equals staying in deferral — yes while the stablecoin remains a digital asset, no the moment it becomes euros again. The other trap: paying fees or subscriptions in crypto without seeing a disposal in it.

The deferral erases nothing: it accumulates. Years of happy arbitrage compress into the single disposal that touches euros — computed by the global portfolio formula, at the rate of the exit day, not of the swap days.

The discipline the deferral still demands

Owing nothing does not mean recording nothing. Every deferred swap reshapes the portfolio whose global value the formula will demand at the next exit — and the total acquisition cost builds from the first euro ever invested. An audit will ask for the whole chain: from euros in to euros out, through every intermediate swap. The deferral spares you paying at each step; it does not spare you being able to tell the story.

What to do

  1. Distinguish the three exits. Euros, goods and services, soulte: before every operation, know whether it stays deferred or triggers.
  2. Treat stablecoins as crypto — until the euros. The swap into USDC is deferred; the sale of USDC for euros is not.
  3. Log the swaps even when untaxed. Dates, amounts, counter-values: the raw material of the formula on the day of the real exit.
  4. Plan the exit into euros as a major tax event. Years of deferral can unwind in one disposal — the amount is computed before, not after.
The flat tax and the formulaThe computation waiting at the end of the deferral.→ Form 3916-bisThe duty that runs even in years without a single disposal.→

This page explains a deferral mechanism. It is not advice on your operations, and reading it creates no professional relationship.