France vs El Salvador
Crypto regulation comparison
France
El Salvador
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199), El Salvador amended the law to make Bitcoin acceptance by businesses voluntary rather than mandatory, and repealed several articles.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.
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