Denmark vs France
Crypto regulation comparison
Denmark
France
Cryptocurrency is legal in Denmark and regulated under EU frameworks including MiCA. Denmark has notably high tax rates on crypto gains, treated as personal income and taxed at rates up to 52%. The Danish Tax Council confirmed in 2018 that gains and losses on Bitcoin are taxable.
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 gains taxed as personal income at 37-52% (among the highest in the world)
- Losses on crypto can be deducted against gains
- Finanstilsynet supervises crypto businesses under the Danish AML Act
- Denmark does not have its own crypto-specific legislation beyond EU frameworks
- Skattestyrelsen (tax authority) actively monitors crypto transactions and issues guidance
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