France vs Malta
Crypto regulation comparison
France
Malta
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).
Malta positioned itself as the 'Blockchain Island' with the 2018 Virtual Financial Assets (VFA) Act, one of the world's first comprehensive crypto regulatory frameworks. The MFSA licenses VFA service providers and oversees ICOs. Long-term crypto holdings are generally not subject to capital gains tax for individuals, while trading profits may be taxed as income.
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 Financial Assets Act (2018) provides a comprehensive licensing framework
- MFSA licenses VFA exchanges, brokers, custodians, and portfolio managers
- Long-term crypto holdings generally not subject to capital gains tax for individuals
- Day trading profits may be taxed as business income at progressive rates up to 35%
- Transitioning to EU MiCA framework from December 2024