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For a French tax resident managing cryptocurrency as private wealth, swapping one qualifying digital asset for another without a cash adjustment (a soulte) is generally tax-deferred, not immediately taxable. The exchange is treated as an interim transaction under Article 150 VH bis of the French General Tax Code. Tax normally becomes relevant when you later dispose of the asset for euros or another legal tender, goods, services, or in a transaction with a cash adjustment.
The current Direction générale des Finances publiques (DGFiP) FAQ, modified July 17, 2026, states a 31.4% flat tax (12.8% income tax plus 18.6% social levies) for taxable private-investor gains, subject to the tax year and the taxpayer’s option for the progressive income-tax scale. Always check the rate and forms for the income year you are filing.
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The basic rule: a no-cash crypto swap is deferred
French guidance calls an exchange without a cash adjustment between digital assets, or rights relating to them, an “interim” transaction that benefits from tax deferral. In practical terms, exchanging Bitcoin for Ether, or one token for another, does not by itself trigger the private-investor capital-gain calculation when no euros or other cash adjustment is paid. The deferred treatment is described by the DGFiP in its official disposal guidance: official guidance on disposals of movable property.
Deferral is not an exemption. The economic history of the assets remains relevant to the portfolio calculation when a later taxable disposal occurs. Keep the date, assets, quantities, exchange rate, fees and wallet or platform records for every swap even when the swap itself is not reported.
What counts as a taxable disposal
The no-soulte rule does not cover every transaction described by an exchange interface as a “swap.” A disposal can be taxable when you:
- sell digital assets for euros or another legal tender;
- exchange digital assets for goods or services;
- make an exchange that includes a cash adjustment (a soulte); or
- carry out another transaction that is legally characterized as a disposal rather than an exchange without a cash adjustment between qualifying digital assets.
The official guidance treats exchanges with a cash adjustment, and exchanges for legal tender, non-digital goods or services, as taxable disposals. The exact amount of any gain or loss is then determined using the portfolio-wide method rather than the profit shown on a single coin position.
How the French private-investor calculation works
For a taxable disposal, France does not simply compare the sale price with the purchase price of the particular token sold. The official method allocates a proportion of the total acquisition cost of your digital-asset portfolio to each taxable disposal. The portfolio includes assets held across your storage locations at the time of the disposal.
Official formula: taxable gain or loss = disposal proceeds − [total acquisition cost of the digital-asset portfolio × disposal proceeds ÷ total value of the digital-asset portfolio]. Documented disposal expenses may reduce the disposal proceeds. The formula and the fields needed to apply it are described in the Form 2086 notice and the DGFiP disposal guidance.
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Illustrative portfolio example
Assume, solely as an illustration, that immediately before a taxable sale your digital-asset portfolio is worth €50,000 and its total acquisition cost is €30,000. You dispose of assets for €10,000. The allocated acquisition cost is €30,000 × (€10,000 ÷ €50,000), or €6,000. The resulting gross gain is €10,000 − €6,000 = €4,000 before any permitted disposal expenses.
This example is not a special rule for a particular coin. The same portfolio-wide approach applies whether the disposal follows years of purchases, several deferred crypto-to-crypto exchanges, or assets held in multiple wallets and platforms. Your records must support both the portfolio value and the total acquisition cost at each taxable disposal.
Current rate and the €305 small-disposal threshold
31.4% PFU for the private-investor regime
The DGFiP FAQ modified July 17, 2026, states that private-investor gains are subject to a 31.4% prélèvement forfaitaire unique (PFU): 12.8% income tax plus 18.6% social levies. The same FAQ says the taxpayer may opt for the progressive income-tax scale instead. This is a time-sensitive statement; an older BOFiP text that ceased publication in 2024 shows a former 30% total and should not be used as the current rate. Check the applicable rate for the income year concerned in the current DGFiP FAQ.
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For a private investor, the current FAQ describes an exemption when the sum of annual gross proceeds from taxable digital-asset disposals does not exceed €305. Deferred no-soulte crypto-to-crypto exchanges are excluded from that threshold calculation. The test uses the amount received from disposals, not your net profit.
For example, taxable disposals producing €305 or less in total gross proceeds for the year fall within the stated threshold. If your taxable disposal proceeds exceed €305, the exemption no longer applies to that year’s disposals, even if the eventual net gain is small or zero. Keep the threshold separate from the gain calculation: proceeds determine access to the exemption, while the portfolio formula determines the gain or loss.
Which transactions belong in each category?
| Transaction | Typical private-investor treatment | Record or filing implication |
|---|---|---|
| Bitcoin exchanged for Ether with no cash adjustment | Interim exchange; tax deferred under Article 150 VH bis | Retain transaction records; the swap itself is generally not declared as a taxable disposal |
| Token exchanged for euros | Taxable disposal | Include proceeds and portfolio data in the annual calculation |
| Token exchanged for a good or service | Taxable disposal under the official guidance | Use the value of the disposal and retain invoices or other evidence |
| Crypto exchange with a cash adjustment (soulte) | Taxable disposal; no-soulte deferral does not apply | Analyze the transaction as a disposal and include it in the relevant records |
| Liquidity-pool deposit, wrapped-token conversion or bridge | Not specifically settled by the reviewed official materials | Obtain transaction-specific advice rather than assuming automatic deferral or taxation |
The label used by a platform is not decisive. A transaction called a “swap” may include a cash leg, a service, a non-qualifying token or a contract whose legal characterization is uncertain.
How to report taxable disposals
1. Gather transaction and portfolio records
Before completing a return, assemble a chronological ledger covering every wallet, exchange account and custody location. For each taxable disposal, record the date, asset and quantity disposed of, amount received, valuation currency, fees, and the value and acquisition cost of your entire digital-asset portfolio at that time. Preserve records for no-soulte swaps as well, because later calculations may depend on the asset history.
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2. Complete Form 2086
Taxable private-investor disposals are calculated on Form 2086, declaration of gains and losses on disposals of digital assets. The 2026 page identifies a 2026 edition, while the linked notice is specifically titled for income 2025. The edition year and the income year are not interchangeable, so select the form corresponding to the return period you are actually filing.
3. Carry the annual result to the income-tax return
The DGFiP says online filers use annex 2086 and the resulting annual amount is carried to line 3AN for a net gain or line 3BN for a net loss. For a paper return, the FAQ says to report the net result on form 2042 C and provide the transaction details in annex 2086. Follow the instructions displayed for your filing year because labels and electronic workflows can change.
4. Declare foreign digital-asset accounts when required
The DGFiP FAQ also states that foreign digital-asset platform accounts must be declared. This obligation is separate from calculating gains and losses. Review the current filing interface and forms for the accounts you held during the relevant year; do not assume that reporting the gain on Form 2086 satisfies the account declaration requirement.
Your taxpayer status changes the regime
Private management of personal wealth
Article 150 VH bis is the framework for an individual managing digital assets as private wealth. The no-soulte deferral, the portfolio-wide calculation, Form 2086 and the current 31.4% PFU described above belong to this private-investor context.
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The DGFiP FAQ distinguishes commercial purchase-and-resale activity from private asset management. Activity carried out as a commercial business is classified under industrial and commercial profits (BIC), not the private-investor capital-gain regime. The frequency, organization, intention and professional character of the activity matter; a high number of transactions alone is not a substitute for a legal analysis.
Professional-like trading outside one’s profession (BNC)
Professional-like trading that is not treated as a commercial purchase-and-resale business can fall under non-commercial profits (BNC). The DGFiP materials mention a 34% micro-BNC allowance for that professional-like case. That allowance is not available as a shortcut for ordinary private investors and does not change the Article 150 VH bis rules for personal wealth.
If your activity resembles a business, involves leverage or organized trading operations, or is performed through a company, obtain advice based on your facts before applying the private-investor forms.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.DeFi, wrapped assets and bridges: where the rule is not clear
The reviewed official materials do not specifically explain how Article 150 VH bis applies to liquidity-pool deposits, wrapped-token conversions or blockchain bridge transactions. The general legal question is whether the operation is an exchange without a cash adjustment between qualifying digital assets or rights relating to them. Smart-contract mechanics can create several transfers, fees, receipt tokens or claims that do not map neatly onto a simple coin-for-coin exchange.
Do not describe every DeFi action as tax-free merely because no euros were withdrawn, and do not assume every token movement is taxable. Preserve the complete on-chain transaction, identify each asset received or surrendered, document fees and valuations, and ask a French tax professional to characterize unusual transactions for the relevant year.
Recordkeeping checklist for a defensible return
- Export fills, deposits, withdrawals and swap histories from every platform.
- Save wallet addresses and blockchain transaction identifiers for on-chain activity.
- Record the quantity and value of each asset at every taxable disposal.
- Track acquisition contributions and the total portfolio value across all storage locations.
- Separate no-soulte exchanges from sales, purchases of goods or services, and soulte transactions.
- Keep evidence of documented disposal expenses that you claim to reduce proceeds.
- Reconcile platform data with wallet records so transfers between your own accounts are not mistaken for disposals.
- Retain copies of Form 2086, the income-tax return and any foreign-account declaration.
Common mistakes to avoid
- Using the old 30% rate: the current DGFiP FAQ cited above states 31.4% for the private-investor PFU; rates must be checked for the tax year.
- Testing the €305 rule against profit: the threshold concerns annual gross taxable-disposal proceeds, excluding deferred no-soulte exchanges.
- Calculating only the sold coin’s gain: the official formula uses total portfolio acquisition cost and total portfolio value at the disposal date.
- Ignoring a cash adjustment: a soulte removes the protection of the no-soulte interim-exchange rule.
- Assuming a crypto-to-crypto label settles the law: DeFi and wrapped-token mechanics may require transaction-specific characterization.
- Forgetting foreign accounts: the account declaration obligation is separate from Form 2086’s gain or loss calculation.
- Confusing form edition and income year: the 2026 Form 2086 page links to a notice for income 2025, so verify the period before filing.
Bottom line for a French resident
An ordinary exchange of one qualifying digital asset for another, with no cash adjustment, is generally tax-deferred rather than taxed at the moment of the swap. Tax is normally considered when you later sell for legal tender, exchange for goods or services, or undertake a transaction with a cash adjustment. For private investors, taxable disposals are calculated across the whole digital-asset portfolio, reported with Form 2086, and currently described by the DGFiP as subject to a 31.4% PFU, with a progressive-scale option. Because rates, forms and the legal treatment of complex transactions can change, verify the rules for the exact income year and obtain advice for activity that is not straightforward personal investing.
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