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France vs Morocco

Crypto regulation comparison

France

France

Morocco

Morocco

Legal
Restricted

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).

Morocco's central bank (Bank Al-Maghrib) banned cryptocurrency transactions in 2017, making it illegal for financial institutions to process crypto payments. Despite the ban, Morocco has one of the highest crypto adoption rates in Africa. The government has been exploring a potential regulatory framework, with Bank Al-Maghrib reportedly studying a CBDC and reconsidering its crypto stance.

Tax Type Capital gains
Tax Type None
Tax Rate 30%
Tax Rate N/A
Exchanges Yes Yes
Exchanges No No
Mining Yes Yes
Mining Yes Yes
Regulator AMF (Autorité des Marchés Financiers), ACPR
Regulator BAM (Bank Al-Maghrib), AMMC
Stablecoin Rules Regulated under MiCA; stablecoin issuers need e-money or credit institution license
Stablecoin Rules No regulation; crypto transactions banned by central bank
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
  • Bank Al-Maghrib banned crypto transactions for financial institutions in 2017
  • Crypto ownership is technically in a legal gray area; trading happens via P2P
  • Morocco ranks among the top crypto adopters in Africa despite the ban
  • Government exploring regulatory framework and potential CBDC
  • No crypto taxation framework exists due to the ban