Crypto Wealth Tax: Prospective Scenario for France

Analysis of warning signs and anticipation of potential crypto wealth taxation

December 2025 | Prospective Article | Category: Regulation

Table of Contents

1. Introduction: A Latent Threat
2. Current Tax Situation for Crypto-Assets
3. Past Legislative Proposals
4. The Norwegian Precedent
5. Arguments For and Against IFI Inclusion
6. Possible Implementation Scenarios
7. Anticipation Strategies
8. Numerical Simulations
9. Conclusion: Probability and Recommendations
10. FAQ
11. Sources and References

1. Introduction: A Latent Threat

When parliamentarians dream of taxing your Bitcoins like your apartments

Every year, during budget debates in the National Assembly, the same question comes up with clockwork regularity: should crypto wealth be taxed like real estate?

In France, the Real Estate Wealth Tax (IFI) applies to net real estate assets exceeding 1.3 million euros. Crypto-assets currently remain excluded from this tax base. But for how much longer?

This article provides a prospective analysis of the risks of including crypto-assets in a wealth tax, whether through an extension of the existing IFI or the creation of a new specific tax.

⚠️ Disclaimer: This article is a prospective analysis and does not constitute tax advice. The situation described reflects the state of law and legislative proposals as of December 2025. Consult a professional for your personal situation.

Why This Topic Now?

Several factors are converging to make this hypothesis increasingly credible:

2. Current Tax Situation for Crypto-Assets

The existing regime before any wealth tax extension

2.1 Legal Classification

Under French law, crypto-assets are classified as intangible movable property. This classification, confirmed by the Council of State, has important implications:

• They are not financial instruments under the Monetary and Financial Code
• They are not currencies or money
• They are comparable to sui generis intangible assets

2.2 Current Tax Regime (Reminder)

Capital Gains Taxation (Individuals)

"Capital gains from occasional disposal of digital assets by individuals are subject to the 30% flat tax."

Source: Article 150 VH bis of the General Tax Code

2.3 Current Exclusion from IFI

The IFI, established in 2018 to replace the ISF, has a scope strictly limited to real estate assets:

"Subject to real estate wealth tax [...] are natural persons [...] in respect of their real estate assets."

Source: Article 964 of the General Tax Code

Crypto-assets, being intangible movable property and not real estate assets, are therefore automatically excluded from the IFI tax base.

Practical consequence: A taxpayer owning €5 million in Bitcoin and €500,000 in primary residence pays... zero euros in IFI (net real estate below the €1.3M threshold).

3. Past Legislative Proposals

Review of recurring amendment attempts in the Assembly

3.1 Amendment Chronology

Since 2021, several amendments aimed at taxing crypto wealth have been submitted during budget debates:

3.2 Arguments Made by Proponents

Deputies submitting these amendments generally invoke:

1. Tax Equity

"It is not acceptable that considerable wealth escapes any form of wealth contribution simply because it is invested in digital assets rather than real estate."

Source: Statement of reasons, Amendment I-CF768, PLF 2024

2. Budget Revenue Estimates vary, but proponents cite potential revenue of €300 to €800 million per year, depending on wealth assumptions and thresholds retained.

3. Tax System Consistency The argument for consistency with other wealth assets (stocks, bonds, art) that were subject to the former ISF.

3.3 Reasons for Successive Rejections

Amendments have been systematically rejected for several reasons:

3.4 The 2025 Amendment: An Important Weak Signal

For the first time in December 2025, an amendment requesting an impact study on including crypto-assets in a wealth tax base was adopted. While it doesn't create a new tax, it shows an evolution in parliamentary attitudes.

4. The Norwegian Precedent

The only European country that already taxes crypto wealth

4.1 Norway Already Taxes Crypto Wealth

Norway is one of the few European countries to have explicitly included crypto-assets in its wealth tax (Formueskatt) base.

Norwegian System Characteristics:

4.2 Application to Crypto-Assets

Since 2018, Norwegian tax authorities (Skatteetaten) require declaration of all crypto-assets in taxable wealth:

"Cryptocurrencies are considered taxable assets. The value on January 1st of the tax year must be declared."

Source: Skatteetaten, Crypto-Asset Tax Guide 2024

Valuation Method:

• Market price at midnight January 1st (Norwegian time)
• If multiple platforms, average of prices
• If unlisted token, good faith estimate

4.3 Results and Effectiveness

Revenue Generated:

• Estimate: 50-100 million NOK per year (€5-10M)
• Relatively modest compared to total wealth tax

Observed Effects:

• Increased crypto wealth declarations
• Some tax exile cases to other Nordic countries
• Recurring political debate on relevance of this taxation

4.4 Transposability to France

5. Arguments For and Against IFI Inclusion

The debate between tax equality and capital flight risk

5.1 Arguments in Favor of Taxation

Horizontal Equity Two estates of equal value should bear comparable tax burden, regardless of composition. A €3 million real estate portfolio is taxed under IFI, but not a €3 million Bitcoin portfolio.

Additional State Revenue In a context of record public deficit, any new revenue source is studied. High estimates cite €500-800M annual revenue.

New Visibility Thanks to DAC8 From 2027, tax authorities will have automatic knowledge of crypto holdings on regulated platforms, making taxation technically possible.

Consistency with Former ISF The former ISF included securities (stocks, bonds). Excluding crypto from any wealth tax breaks with this historical logic.

5.2 Arguments Against Taxation

Extreme Volatility

Taxing wealth on January 1st that can lose 50% of its value in three months poses a manifest equity problem.

No Recurring Income Unlike real estate that generates rent to pay the tax, crypto-assets don't produce guaranteed income. The taxpayer would have to sell part of their assets to pay the tax — it's a capital tax, not an income tax.

Massive Tax Exile Risk Crypto-assets are, by nature, easily relocatable. A taxpayer can transfer their wealth in minutes to a wallet in another jurisdiction. The ISF experience showed the limits of taxing mobile capital.

Potential Double Taxation Capital gains are already taxed at 30% upon disposal. Adding an annual holding tax would create double taxation of the same wealth.

Valuation Difficulty How to value:

• Unlisted tokens?
• DeFi positions (LP tokens, staking)?
• NFTs?
• Crypto on undeclared self-custody wallets?

IFI Philosophy The IFI was created with specific logic: tax real estate because it's an "unproductive" asset that doesn't create jobs. This logic doesn't apply to crypto.

6. Possible Implementation Scenarios

IFI extension, dedicated tax, or mandatory declaration

6.1 Scenario 1: Pure IFI Extension to Crypto-Assets

Description: Modify Article 964 of the CGI to include "digital assets within the meaning of Article L. 54-10-1 of the CMF" in the IFI base.

Likely Terms:

• Same scale as current IFI (0.5% to 1.5%)
• Same threshold (€1.3M total wealth)
• January 1st valuation

Current IFI Scale (for reference):

Probability: Low in short term (political complexity of reopening IFI debate)

6.2 Scenario 2: Creation of a Specific Crypto Tax

Description: Create a new autonomous tax, distinct from IFI, specifically targeting crypto portfolios.

Advantages for the Legislator:

• Avoids reopening IFI extension debate
• Allows adapted terms (thresholds, rates, valuation)
• Strong political signal without touching existing

Possible Terms:

• Specific threshold (e.g., €300,000 or €500,000 in crypto)
• Moderate rate (e.g., 0.3% to 0.5%)
• Holding period allowance

Probability: Medium at 3-5 year horizon

6.3 Scenario 3: Return of ISF Including Crypto

Description: Reinstatement of a global Wealth Tax (pre-2018 ISF type) including all assets, including crypto-assets.

Political Context: Several political parties (left, greens) support ISF return. In this scenario, crypto would naturally be included like any other asset.

Probability: Depends on political changes — medium long-term

6.4 Scenario 4: Prolonged Status Quo

Description: Amendments continue to be rejected, crypto remains excluded from any wealth tax.

Maintenance Factors:

• Effective crypto lobby (ADAN)
• Fear of tax exile
• Unresolved technical complexity
• Political priorities elsewhere

Probability: High in short term (1-2 years)

7. Anticipation Strategies

How to prepare before potential wealth taxation

7.1 Legal Optimization Strategies

1. Advance Donation

Crypto-asset donation allows:

• Wealth transfer with allowances (€100,000 parent→child / 15 years)
• Purge latent capital gain
• Reduce donor's taxable wealth

2. Structuring via Company

Holding crypto-assets through a company (SAS, holding) can offer:

• Separation from personal wealth
• Capital gains tax optimization (corporate vs individual)
• But beware: company shares could themselves be taxable

3. Luxembourg Life Insurance

Some Luxembourg life insurance contracts accept crypto-assets as underlying. The life insurance wrapper benefits from a specific tax regime.

7.2 Tax Relocation

Conditions for Change of Tax Residence:

• Effective transfer of domicile
• Center of economic interests abroad
• Physical presence > 183 days outside France

Exit Tax: Upon departure, latent capital gains on crypto-assets held may be subject to exit tax (Article 167 bis CGI), with payment deferral under conditions.

Attractive Jurisdictions:

⚠️ Warning: Relocation must be real and genuine. Fictitious relocation constitutes tax fraud.

7.3 Documentation and Preparation

Regardless of legislative evolution, it is recommended to:

1. Document complete history of acquisitions
2. Keep proof of purchase prices
3. Track valuation on January 1st each year
4. Use tracking tools (Waltio, Koinly)
5. Consult a tax specialist in crypto

8. Numerical Simulations

How much would you pay under different scenarios

8.1 Methodology

The simulations below illustrate potential impact under different scenarios, for 100% crypto wealth (extreme case for illustration).

Assumptions:

• Valuation on January 1, 2026
• Current IFI scale applied
• No other wealth assets

8.2 Simulation: €500,000 Portfolio

8.3 Simulation: €2,000,000 Portfolio

IFI Calculation Detail on €2M:

• €0 to €800k: €0
• €800k to €1.3M: €500k × 0.5% = €2,500
• €1.3M to €2M: €700k × 0.7% = €4,900
• Total: ~€7,400 + possible discount

8.4 Simulation: €5,000,000 Portfolio

8.5 The Volatility Problem Illustrated

The taxpayer would have paid €5,000 in 2024 on wealth worth €600,000 three months later — an effective rate of 0.83%.

9. Conclusion: Probability and Recommendations

Our risk analysis and actions to consider

9.1 Probability Assessment

Potential Triggers:

• Major budget crisis
• Political change (left return to power)
• Sharp crypto price rise making portfolios visible
• European pressure for harmonization

9.2 Recommendations

Short Term (Now)

1. ✅ Precisely document your crypto portfolio
2. ✅ Keep purchase price evidence
3. ✅ Follow parliamentary debates (annual PLF)
4. ✅ Consult a tax advisor if portfolio > €500k

Medium Term (If Taxation Signals)

1. 📋 Evaluate donation strategies
2. 📋 Study company structuring
3. 📋 Analyze relocation options (if relevant)

Long Term (Wealth Strategy)

1. 🎯 Integrate tax risk into asset allocation
2. 🎯 Diversify geographically if significant wealth
3. 🎯 Maintain active regulatory watch

9.3 Final Word

Inclusion of crypto-assets in a wealth tax remains, to date, a hypothesis and not a certainty. Technical, political, and economic obstacles are real. However, the evolving context — increased wealth visibility, budget pressure, foreign precedents — suggests this question will inevitably return to the table.

Prudence dictates preparing without panicking, by documenting your wealth and staying informed of legislative developments.

10. FAQ

Q1: Are crypto-assets currently subject to IFI?

No. The IFI only concerns real estate assets. Crypto-assets, being intangible movable property, are excluded from its base.

Q2: If a crypto wealth tax were created, would it be retroactive?

Very unlikely. The principle of tax non-retroactivity is constitutionally protected. A new tax would apply from its effective date.

Q3: How would the tax authority know my crypto portfolio?

From 2027, the DAC8 directive requires platforms to automatically transmit information on crypto holdings. Self-custody wallets remain outside this scope (for now).

Q4: Can I escape this tax by going self-custody?

In theory, self-custody wallets are less visible. However, any previous passage through a regulated exchange leaves traces. Moreover, the December 2025 amendment on self-custody wallet declaration shows the legislator is interested in this question.

Q5: Does crypto-asset donation purge the capital gain AND reduce taxable wealth?

Yes for both. Donation purges the latent capital gain (donee starts with a new acquisition price) and reduces the donor's wealth for calculating any potential wealth tax.

Related Articles — Regulation

• DAC8 Automatic Exchange of Crypto Information
• AMLR Anonymous Crypto Payments Europe
• Travel Rule Crypto Transfers Europe
• NFT Regulation Europe MiCA

11. Sources and References

Legislative and Regulatory Texts

• Article 964 of the General Tax Code - IFI tax base
• Article 150 VH bis of the CGI - Crypto capital gains taxation
• Article L. 54-10-1 of the Monetary and Financial Code - Digital asset definition
• Parliamentary amendments - PLF 2022 to 2026 (assemblee-nationale.fr)

Tax Sources

• BOFiP - BOI-PAT-IFI (Real Estate Wealth Tax)
• BOFiP - BOI-RPPM-PVBMC (Digital asset capital gains)
• Court of Auditors Report - Tax fraud in France (2023)

International Sources

• Skatteetaten (Norway) - Crypto-asset guidelines
• OECD - Reports on digital asset taxation
• European Commission - Studies on crypto-asset taxation

Analyses and Studies

• ADAN (Association for Digital Asset Development) - Positions
• KPMG/ADAN Study 2024 - Crypto-asset adoption in France
• CMS Francis Lefebvre - Crypto tax analyses

Document written in December 2025

This article is a prospective analysis. The tax situation may evolve. Consult a professional for advice suited to your situation.