France vs Japan
Crypto regulation comparison
France
Japan
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).
Japan is one of the world's most comprehensively regulated crypto markets. The Payment Services Act and Financial Instruments and Exchange Act govern crypto exchanges and tokens. Japan classifies crypto as "crypto-assets" and taxes gains as miscellaneous income at rates up to 55%, though reforms to lower this rate are under active discussion.
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
- Crypto exchanges must register with the FSA under the Payment Services Act
- Crypto gains taxed as miscellaneous income at up to 55% (national + local tax)
- Japan's self-regulatory body JVCEA sets industry standards for exchanges
- 2022 stablecoin legislation (revised Payment Services Act) regulates stablecoin issuance
- Government considering tax reform to apply a flat 20% separate taxation on crypto gains
Sources
Sources
- NTA - Crypto Assets Tax Pamphlet
- FSA - Registered Crypto-Asset Exchanges
- FSA - Regulating Crypto Assets in Japan
- NTA - Tax Answer No. 1524 (暗号資産)
- NTA - Income Tax Guide 2025 (English PDF)
- Japanese Law Translation - Payment Services Act
- FSA - Discussion Paper on Cryptoasset Regulatory Systems
- FSA - Registered Electronic Payment Instrument Exchanges