This English page mirrors the French reference page for international clients. It is written for decision-makers who need a clear first reading before a tailored French tax analysis.
Crypto-assets are not all treated alike
A private holding of crypto-assets is not necessarily within the classical exit tax perimeter, which is primarily built around shares, securities and certain rights. The analysis changes when the exposure is held through a company, fund, tokenised security or professional structure.
Private crypto gains
Private crypto gains require a separate analysis under the French tax rules applicable to digital assets. A departure from France does not automatically create the same result as a sale of shares, but the factual situation must be reviewed.
Company-held crypto exposure
If crypto exposure is held through a company whose shares are within the exit tax perimeter, the value of that exposure may affect the valuation of the shares. The risk is therefore indirect but very real.
Professional activity and recharacterisation
A taxpayer operating at scale may face a separate recharacterisation issue. The question is not only exit tax but also whether the activity is private, professional or carried through an entity.
Practical file
The taxpayer should document wallets, exchanges, custody arrangements, company accounts, token nature and the link between personal assets and corporate assets before leaving France.
Direct crypto ownership and company shares are different questions
French exit tax is defined by reference to specific securities, rights, receivables and deferred gains. A privately held digital asset is therefore not automatically treated in the same way as a share. The first task is to classify what the taxpayer legally owns. Direct tokens held in a personal wallet, units or shares in an investment vehicle, shares in an operating company that owns crypto-assets, and a professional trading business can lead to different French tax analyses.
Where an individual owns shares in a company whose main assets are cryptocurrencies, the object potentially tested under Article 167 bis is the shareholding. The company's wallets, custody arrangements, liabilities and trading exposure then influence the value of those shares. The analysis should not simply substitute the spot value of the tokens for the market value of the company: cash, debt, tax liabilities, governance restrictions and liquidity may also matter.
Records needed at the transfer date
- a wallet and exchange inventory, distinguishing personal assets from company assets;
- transaction histories and evidence of acquisition cost, including token swaps and transfers between wallets;
- the legal terms of staking, lending, custody or decentralised-finance positions;
- company accounts, treasury policies and proof of beneficial ownership;
- the pricing source, timestamp and foreign-exchange rate used for a valuation;
- an explanation of whether activity is private investment or is carried on under professional conditions.
Crypto markets trade continuously and can be volatile. A file should therefore state the exact valuation date and time, the exchange or pricing methodology selected and how illiquid or restricted positions were treated. Screenshots alone are weak evidence; downloadable histories, signed accounts, wallet-address records and an explanation of methodology are more useful.
After the move
Moving abroad does not erase French-source obligations or the consequences of a pre-existing deferral. A later sale of company shares, a liquidation or a transaction affecting gains already under deferral may need to be reported. Conversely, a later disposal of directly held tokens should not be forced into the exit-tax framework merely because the holder previously lived in France; residence, source, treaty and the specific crypto regime must be reviewed at that later date.
The starting primary source is the current Article 167 bis CGI. Because the legal classification of digital-asset arrangements depends on their rights and facts, this page does not state that every token is included or excluded. Obtain a transaction-level review where assets are held through a company, an investment instrument or a professional activity.