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France vs Lithuania

Crypto regulation comparison

France

France

Lithuania

Lithuania

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).

Cryptocurrency is legal and regulated in Lithuania. The Bank of Lithuania oversees VASPs under AML regulations and has been an early mover in crypto regulation within the EU. Lithuania attracted a large number of VASP registrations due to initially favorable conditions, though it tightened requirements significantly in 2022-2023. The MiCA framework now applies.

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 30%
Tax Rate 15%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator AMF (Autorité des Marchés Financiers), ACPR
Regulator Bank of Lithuania (Lietuvos Bankas)
Stablecoin Rules Regulated under MiCA; stablecoin issuers need e-money or credit institution license
Stablecoin Rules Regulated under EU MiCA 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
  • VASPs must register with the Bank of Lithuania under AML/CFT law
  • Capital gains from crypto taxed at 15% personal income tax rate
  • Lithuania became a major EU hub for crypto companies; over 500 VASPs registered by 2022
  • Tightened VASP requirements in 2022-2023, including local substance and capital requirements
  • MiCA transition underway from December 2024