BNC vs PFU for Crypto in France

Most people treat French crypto tax as one regime; the costliest assumption in the whole area is that "crypto tax in France = 31.4%". It is two regimes, and this article draws the line between them. The PFU is a flat tax on an occasional investor's capital gains. The BNC regime catches crypto income — staking, mining, lending, DeFi yield — and professional trading. A typical holder lands in both in the same year. Where the gain itself is computed is the 150 VH bis guide; whether your trading tips into professional BNC is occasional vs habitual trader. The pillar is the France crypto tax guide.

Key points

• PFU (31.4% in 2026): an occasional investor's capital gains on disposals (article 150 VH bis).
• BNC: crypto income (staking, mining, lending, DeFi yield) at receipt, and habitual/professional trading (moved from BIC to BNC by the Loi de Finances 2022, effective 2023).
• Staking touches both: BNC at receipt, then PFU on a later disposal (cost basis = receipt value).
• Micro-BNC applies a flat 34% deduction (minimum €305) under the micro threshold (€83,600); above it, the déclaration contrôlée applies.
• PFU and BNC coexist for the same person in the same year; they are 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).

Checking a tool covers both regimes

Most crypto-tax tools handle the disposal side well and quietly under-cover the income side, which is exactly the half people forget. Before relying on a tool here, confirm it:

• computes the disposal side under the 150 VH bis method at the 2026 PFU of 31.4%;
• flags reward income (staking, mining, lending, DeFi yield) as BNC at its fair-market value on the receipt date, not only when the tokens are later sold;
• carries that receipt-date value forward as the cost basis for the later PFU disposal, so the same value is not taxed twice or dropped;
• surfaces activity metrics (frequency, volume) without pretending to settle the professional-classification question.

Waltio is French-specialised and Koinly supports the French regime; both compute the PFU disposal side. The BNC-at-receipt side is the part to verify, and neither tool decides whether your trading is professional.

How Wag3s fits in

Wag3s Folio separates disposals (PFU / 150 VH bis) from reward income (BNC at receipt fair-market value), so both taxable moments are captured rather than only the disposal, and it reconciles against DAC8-reported activity. The professional-versus-occasional classification is a legal judgement on a bundle of facts; Folio supplies the documented history for it, and is designed to support a qualified French expert-comptable who makes the call, not to make it itself.

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

Worked example: staker with occasional disposals

Amélie is an occasional investor who also stakes ETH on the Ethereum mainnet. In 2025:

• She earns staking rewards totalling 0.15 ETH, valued at €300 at the time the rewards became available to her (i.e., at control).
• She later sells 0.5 ETH (acquired for €600 total cost) for €1,500.

BNC at receipt (staking rewards).

• Income to declare: €300 (fair-market value at control date, 0.15 ETH).
• Under micro-BNC (assuming she has no other BNC activity and is under the €83,600 threshold): taxable base = €300 × (1 − 34%) = €198. This is added to her other income and taxed at the progressive IR scale.
• The 0.15 ETH now has a cost basis of €300 for any future disposal.

PFU on the disposal (150 VH bis).

• Disposal proceeds: €1,500.
• Total portfolio acquisition cost: let's assume €6,000. Total portfolio value at disposal: €18,000.
• Proportional acquisition cost = €6,000 × (€1,500 / €18,000) = €500.
• Net gain = €1,500 − €500 = €1,000.
• €305 test: total disposals = €1,500 > €305 → fully taxable.
• Tax: €1,000 × 31.4% = €314.

Common error. Many stakers declare only the €314 on the disposal and forget the €300 BNC at receipt. The DGFiP cross-references on-chain staking data as part of DAC8 reporting; from 2026 this under-declaration is more likely to be detected. Both taxable events must be declared.

Total tax position for Amélie in 2025:

• BNC income tax on micro-BNC base: €198 × applicable marginal rate (e.g. 30% TMI) ≈ €59.
• PFU on disposal gain: €314.
• Combined: approximately €373 — not €314.

Sources

• Légifrance — Article 150 VH bis CGI: the occasional-investor capital-gains regime (PFU side).
• Légifrance — Article 92 CGI: the BNC definition, including digital-asset buy/sell/exchange carried out under conditions analogous to a professional activity.
• BOFiP — Régime fiscal des opérations d'achat, de vente et d'échange d'actifs numériques effectuées dans des conditions analogues à un professionnel (loi n° 2021-1900, art. 70): the BIC-to-BNC reclassification and its exceptional, case-by-case scope.
• Légifrance — Article 200 C CGI: the flat-rate treatment of occasional-investor gains.
• Council Directive (EU) 2023/2226 (DAC8) — EUR-Lex.