BNC vs PFU for Crypto in France

The single most common French crypto-tax confusion is treating it as one regime. It is two. Occasional capital gains are taxed at the PFU (31.4% in 2026). Crypto income — staking, mining, lending, DeFi yield — and professional trading are taxed under BNC. Most holders touch both in the same year. This guide is the decision map.

TL;DR

• PFU (31.4% in 2026): occasional investors' capital gains on disposals (article 150 VH bis).
• BNC: crypto income (staking, mining, lending, DeFi yield) at receipt, and habitual/professional trading (BIC → BNC since Loi de Finances 2022, effective 2023).
• Staking touches both: BNC at receipt → PFU on later disposal (cost basis = receipt value).
• Micro-BNC: flat 34% deduction (min €305) under the micro threshold (€83,600); else déclaration contrôlée.
• PFU and BNC coexist for the same person in the same year — not mutually exclusive.

The two regimes, precisely

PFU is a flat capital-gains tax. BNC is an income regime. The error is assuming "crypto tax in France = 31.4%." That is only the occasional-investor disposal side. Reward income is BNC; professional trading is BNC.

Staking, mining, lending, DeFi: BNC at receipt

Crypto received as a reward — staking, mining, lending interest, liquidity-mining/DeFi yield — is BNC income at receipt, valued at fair-market value when the rewards become available. Then:

1. At receipt: BNC income (taxable that year at the BNC treatment).
2. At later disposal: a separate capital-gains event under PFU/150 VH bis, with cost basis = the value taxed at receipt.

So a staker has two taxable moments per reward: BNC at receipt, PFU on disposal. Ignoring the receipt-side BNC is a frequent under-declaration (the disposal-side PFU is what most tools surface; the BNC at receipt is easy to miss).

When trading becomes professional BNC

Habitual/professional trading moved from BIC to BNC under the Loi de Finances 2022 (effective 1 January 2023), aligned with the regime for stock-market operations. Whether you are professional is a bundle-of-factors test (see occasional vs habitual trader for the full criteria). Practitioner guidance commonly flags indicators such as:

• A high number of operations per year
• Crypto income representing a large share of household income
• Professional organisation or sophisticated tools (bots, leverage, derivatives)

There is no single statutory number — it is assessed case by case by the DGFiP. Sustained, organised, high-volume activity is the risk zone. If reclassified, the disposal side itself moves into BNC (not just the reward income).

Micro-BNC vs déclaration contrôlée

Within BNC there are two sub-regimes:

Micro-BNC is administratively light but the 34% flat deduction rarely matches real crypto expenses. The déclaration contrôlée lets you deduct actual expenses (exchange fees, gas, software, hardware) but requires real accounting and FEC capability (see France crypto tax guide for the FEC requirement).

PFU and BNC coexist

A normal holder in a single year:

• Sells some crypto to fiat → PFU (150 VH bis), 31.4%.
• Earned staking rewards → BNC at receipt; later disposal of those tokens → PFU.

Both appear on the same return. They are not mutually exclusive. Only a habitual/professional classification shifts the disposal side from PFU to BNC; for everyone else, the disposal stays PFU while reward income is BNC.

Practical workflow

1. Separate disposals from reward income in your history.
2. Disposals (occasional) → PFU 150 VH bis at 31.4% (apply the €305 test first).
3. Reward income (staking/mining/lending/DeFi) → BNC at receipt FMV.
4. Assess the habitual/professional risk — if professional, the disposal side also becomes BNC.
5. Within BNC, choose micro-BNC (34%) or déclaration contrôlée by threshold/election.
6. Reconcile against DAC8-reported data (see DAC8 impact on individuals).

How vendor tools handle PFU vs BNC

Waltio (French-specialised) and Koinly compute the PFU disposal side well; the BNC-at-receipt side for staking/mining/DeFi is the part to verify — confirm the tool flags reward income as BNC at receipt FMV, not only the later disposal. Neither tool decides the professional-classification question.

How Wag3s helps

Wag3s Folio separates disposals (PFU/150 VH bis) from reward income (BNC at receipt FMV), so both taxable moments are captured rather than only the disposal, and reconciles against DAC8-reported activity. See the Folio product page.

Further reading

• France Crypto Tax Guide 2026
• Occasional vs Habitual Trader (France)
• Cerfa 2086 Explained
• PFU vs Barème: Choosing in France
• France Crypto Loss Treatment
• DAC8 Impact on Individuals

Sources

• Article 150 VH bis CGI (occasional investor capital gains) — Légifrance
• Article 92 CGI (BNC) and the micro-BNC regime (34% deduction, €83,600 threshold)
• Loi de Finances 2022 (effective 1 January 2023) — professional crypto trading moved from BIC to BNC
• Council Directive (EU) 2023/2226 (DAC8) — EUR-Lex