French exit tax

Crypto-assets and French exit tax

French exit tax and crypto-assets: scope, private wallets, companies, tokenised securities and residence transfer issues.

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.

This page provides general information only. French tax residence, exit tax, impatriation and cross-border reporting must always be analysed on the basis of the taxpayer’s facts, documents and applicable treaties.
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