China vs France
Crypto regulation comparison
China
France
Banned
Legal
China has imposed a comprehensive ban on cryptocurrency activities. In September 2021, the PBOC and ten other agencies jointly declared all cryptocurrency transactions illegal, and the State Council banned crypto mining. China is instead promoting the digital yuan (e-CNY) CBDC.
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
Unclear
Tax Type
Capital gains
Tax Rate
N/A
Tax Rate
30%
Exchanges
No
Exchanges
Yes
Mining
No
Mining
Yes
Regulator
PBOC (People's Bank of China), CBIRC, CSRC
Regulator
AMF (Autorité des Marchés Financiers), ACPR
Stablecoin Rules
Not applicable; all crypto activities are banned
Stablecoin Rules
Regulated under MiCA; stablecoin issuers need e-money or credit institution license
Key Points
- All crypto transactions declared illegal by PBOC and 10 agencies in September 2021
- Crypto mining banned by the State Council in 2021 after a series of provincial crackdowns
- Financial institutions and payment companies prohibited from facilitating crypto services
- China actively developing and piloting the digital yuan (e-CNY) CBDC
- Despite the ban, some Chinese citizens reportedly access crypto via VPNs and OTC desks
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