France vs Kuwait
Crypto regulation comparison
France
Kuwait
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).
Kuwait has taken a restrictive approach to cryptocurrency. The Central Bank of Kuwait and the Capital Markets Authority have prohibited banks and financial institutions from processing crypto transactions. There is no licensing framework for crypto exchanges. However, owning crypto is not explicitly illegal, and there is no personal income tax in Kuwait, so no crypto-specific tax applies.
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
- CBK prohibits banks and financial institutions from dealing in virtual currencies
- No licensing framework exists for crypto exchanges or VASPs
- Personal ownership of crypto is not explicitly criminalized
- No personal income or capital gains tax in Kuwait applies to crypto
- CMA has warned investors about the risks of cryptocurrency