France vs New Zealand
Crypto regulation comparison
France
New Zealand
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 in New Zealand and treated as a form of property for tax purposes. The IRD taxes crypto depending on the purpose of acquisition — if bought with the intention to sell, gains are taxable income. New Zealand does not have a formal capital gains tax, but crypto profits are often taxable under income tax rules. Exchanges are not specifically licensed but must comply with AML/CFT requirements.
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
- Crypto treated as property; gains taxable if acquired with intent to dispose
- No formal capital gains tax, but income tax applies to crypto trading profits
- Tax rates from 10.5% to 39% depending on income bracket
- Crypto salary payments are treated as taxable income
- Exchanges must comply with AML/CFT Act and register as reporting entities with DIA