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France vs Kazakhstan

Crypto regulation comparison

France

France

Kazakhstan

Kazakhstan

Legal
Legal

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).

Kazakhstan has a dual approach to crypto regulation. The Astana International Financial Centre (AIFC) operates as a regulated sandbox where licensed crypto exchanges can operate under AFSA supervision. Outside the AIFC, crypto regulation is more restrictive. Kazakhstan became a major mining hub after China's ban but has since tightened mining regulations.

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 30%
Tax Rate 10%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator AMF (Autorité des Marchés Financiers), ACPR
Regulator AFSA (Astana Financial Services Authority), NBK (National Bank of Kazakhstan)
Stablecoin Rules Regulated under MiCA; stablecoin issuers need e-money or credit institution license
Stablecoin Rules AIFC (Astana International Financial Centre) has its own framework for digital assets including stablecoins
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
  • AIFC provides a regulatory sandbox for licensed crypto exchanges and businesses
  • Mining is legal and licensed, with a specific tax on electricity consumption for miners
  • Kazakhstan became the world's second-largest Bitcoin mining country after China's 2021 ban
  • 2022 mining crackdown introduced stricter licensing and energy consumption taxes
  • Outside AIFC, domestic crypto payments and exchanges face greater restrictions