Bhutan vs France
Crypto regulation comparison
Bhutan
France
Legal
Legal
Bhutan has quietly become a significant Bitcoin miner through its government investment arm, Druk Holding & Investments, leveraging hydroelectric power. No tax on crypto.
France has one of Europe's most developed crypto regulatory frameworks. The PACTE law (2019) established the PSAN (prestataire de services sur actifs numériques) registration regime, now transitioning to MiCA licensing. Crypto gains are subject to the 30% flat tax (prélèvement forfaitaire unique).
Tax Type
No tax
Tax Type
Capital gains
Tax Rate
0%
Tax Rate
30%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
Royal Monetary Authority of Bhutan
Regulator
AMF (Autorité des Marchés Financiers), ACPR
Stablecoin Rules
No specific stablecoin regulation
Stablecoin Rules
Regulated under MiCA; stablecoin issuers need e-money or credit institution license
Key Points
- Government entity Druk Holding & Investments mines Bitcoin
- Hydroelectric power used for mining operations
- No income or capital gains tax in Bhutan
- Royal Monetary Authority provides oversight
- One of the few countries with state-level crypto mining operations
Key Points
- 30% flat tax on crypto capital gains (12.8% income tax + 17.2% social charges) for non-professionals
- PSAN registration required by AMF for all crypto service providers (mandatory since 2023)
- Transitioning from PSAN regime to MiCA licensing framework in 2024-2025
- Professional crypto traders may opt for progressive income tax rates
- France is home to major crypto companies including Ledger and Société Générale's FORGE