Canada vs France
Crypto regulation comparison
Canada
France
Canada has a well-developed regulatory framework for cryptocurrency. Crypto trading platforms must register with provincial securities regulators through the CSA, and all crypto businesses must register as money services businesses (MSBs) with FINTRAC. Canada approved spot Bitcoin ETFs in 2021, ahead of most other countries.
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).
Key Points
- Crypto trading platforms must register with CSA provincial regulators
- All crypto dealers must register as MSBs with FINTRAC for AML/KYC compliance
- 50% of capital gains are taxable; business income from crypto is fully taxable
- Canada approved spot Bitcoin and Ether ETFs in 2021, the first major country to do so
- CSA issued Staff Notice 21-327 on obligations for crypto trading platforms
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