France vs Jamaica
Crypto regulation comparison
France
Jamaica
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).
Jamaica has no specific cryptocurrency legislation. The Bank of Jamaica does not regulate or endorse crypto but has not banned it. Jamaica launched its own CBDC, JAM-DEX, in 2022 through the National Commercial Bank. Crypto exists in a legal gray area with no dedicated framework.
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
- No specific cryptocurrency legislation or regulatory framework
- BOJ does not recognize crypto as legal tender but has not banned it
- Jamaica launched the JAM-DEX CBDC in 2022
- FSC Jamaica has not issued specific guidance on crypto asset regulation
- Tax treatment of crypto gains is unclear due to lack of specific guidance