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France vs Saudi Arabia

Crypto regulation comparison

France

France

Saudi Arabia

Saudi Arabia

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).

Saudi Arabia has an ambiguous but generally restrictive approach to cryptocurrency. SAMA has not licensed any crypto exchanges, and financial institutions are warned against dealing in crypto. However, crypto is not explicitly banned by law, and Saudi Arabia has participated in blockchain initiatives (Project Aber with the UAE central bank). No personal income or capital gains tax exists in Saudi Arabia.

Tax Type Capital gains
Tax Type None
Tax Rate 30%
Tax Rate 0%
Exchanges Yes Yes
Exchanges No No
Mining Yes Yes
Mining Yes Yes
Regulator AMF (Autorité des Marchés Financiers), ACPR
Regulator SAMA (Saudi Arabian Monetary Authority), CMA Saudi Arabia
Stablecoin Rules Regulated under MiCA; stablecoin issuers need e-money or credit institution license
Stablecoin Rules No regulation; crypto trading not authorized
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
  • SAMA has not authorized or licensed any cryptocurrency exchanges
  • Financial institutions warned against crypto transactions
  • Crypto not explicitly banned but not regulated; exists in a legal gray area
  • No personal income or capital gains tax in Saudi Arabia
  • Saudi Arabia participated in CBDC experiments (Project Aber with UAE)