France vs South Korea
Crypto regulation comparison
France
South Korea
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).
South Korea is one of the world's largest crypto markets. The Virtual Asset Users Protection Act (VAUPA), effective July 2024, provides comprehensive investor protection including requirements for exchanges to hold user assets in cold storage and carry insurance. All VASPs must register with FIU and comply with strict AML rules under the Specific Financial Information Act. A 20% crypto gains tax (above KRW 2.5 million exemption, raised from the original 250K KRW threshold) has been deferred multiple times and is now scheduled for January 2027.
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
- Virtual Asset Users Protection Act (VAUPA) effective July 2024 — major investor protection law
- VASPs must register with FIU and partner with real-name verified bank accounts
- 20% national tax (22% effective incl. 2% local income surtax) above KRW 2.5M annual exemption (deferred to January 2027)
- Exchanges must hold 80%+ of user assets in cold wallets and carry insurance/reserves
- Only won-denominated trading pairs allowed on major exchanges (Upbit, Bithumb, Coinone, Korbit)