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France vs El Salvador

Crypto regulation comparison

France

France

El Salvador

El Salvador

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).

El Salvador made history in September 2021 by becoming the first country to adopt Bitcoin as legal tender through the Bitcoin Law. However, under a January 2025 IMF agreement (Decreto 199), El Salvador amended the law to make Bitcoin acceptance by businesses voluntary rather than mandatory, and repealed several articles. There is no capital gains tax on Bitcoin. The CNAD regulates digital assets.

Tax Type Capital gains
Tax Type No tax
Tax Rate 30%
Tax Rate 0%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator AMF (Autorité des Marchés Financiers), ACPR
Regulator BCR (Banco Central de Reserva), CNAD (Comisión Nacional de Activos Digitales)
Stablecoin Rules Regulated under MiCA; stablecoin issuers need e-money or credit institution license
Stablecoin Rules USD is the primary currency; Bitcoin-specific legislation in place
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
  • First country to adopt Bitcoin as legal tender in September 2021 via the Bitcoin Law
  • Government developed the Chivo wallet for citizens, offering $30 USD in BTC incentive
  • January 2025 Decreto 199 made merchant Bitcoin acceptance voluntary (IMF condition)
  • No capital gains tax on Bitcoin transactions for individuals
  • Government has been accumulating Bitcoin reserves and launched Bitcoin-backed bonds