France vs Ireland
Crypto regulation comparison
France
Ireland
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).
Cryptocurrency is legal in Ireland and subject to a 33% capital gains tax, one of the higher rates in the EU. The Central Bank of Ireland supervises VASPs under AML regulations, and Ireland follows the EU's MiCA framework. Ireland's status as a European tech hub has attracted crypto businesses.
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
Key Points
- 33% capital gains tax on crypto profits (CGT), with an annual exemption of €1,270
- Income from crypto mining, staking, or airdrops may be treated as income tax
- Central Bank of Ireland registers VASPs under the Criminal Justice (Money Laundering) Act
- MiCA framework applicable from December 2024
- Ireland hosts European headquarters of several major crypto firms