BOFiP Crypto References 2026

When a French crypto position is challenged, "the law says" is only half the answer — the other half is "and the BOFiP applies it like this." This guide maps the official doctrine that governs French crypto tax, what is binding versus interpretive, and the one change that matters for 2026: the barème option is no longer irrevocable.

TL;DR

• Main doctrine: BOI-RPPM-PVBMC-30 (occasional-investor digital-asset disposals) + sub-references (-30-10/-20/-30).
• BOFiP is opposable administrative doctrine — reliable as published — but the law is the CGI (article 150 VH bis).
• 2026 change: the Loi de Finances 2026 ended the irrevocability of the progressive-scale (barème) option — now year-by-year.
• PFU 31.4% (CSG 9.2%→10.6%); 150 VH bis method and €305 threshold unchanged.
• Doctrine is split by activity: disposals (PVBMC) vs reward income/professional (BNC, article 92 CGI).

What BOFiP is, and what it is not

The BOFiP-Impôts (Bulletin Officiel des Finances Publiques) is the French tax authority's published administrative doctrine. Two properties matter:

• It is opposable to the administration: you can rely on the doctrine as it stood for the relevant year (the garantie against the administration changing its reading retroactively to your detriment).
• It is not the law. The binding texts are the CGI (e.g. article 150 VH bis for occasional crypto disposals) and the LPF. BOFiP is how the DGFiP interprets and applies those texts.

Practical consequence: compute from the law (150 VH bis), substantiate with the dated BOFiP in force for the year. Citing an undated "BOFiP says" is weak; citing BOI-RPPM-PVBMC-30-30-YYYYMMDD is the defensible form.

The map of references

The structural point: the doctrine is split by activity type. Occasional disposals are in the PVBMC-30 series (PFU/150 VH bis). Reward income and professional trading are BNC (since the Loi de Finances 2022). A filing that uses the disposal doctrine for staking income is using the wrong branch.

The 2026 change: barème option no longer irrevocable

The headline doctrinal/legal change for 2026: the Loi de Finances 2026 ended the irrevocability of the option for the progressive income-tax scale (barème). Previously the election against the PFU could be treated as a locked, one-way choice; for 2026 it is a year-by-year decision. This matters for the PFU vs barème analysis: a low-bracket year can take the barème without permanently forgoing the PFU in later years.

Two other 2026 points, for completeness (unchanged method, changed rate):

• PFU rate: 31.4% (12.8% + 18.6%; CSG on capital income rose 9.2%→10.6%).
• 150 VH bis portfolio method and the €305 all-or-nothing threshold: unchanged.

How to use BOFiP references when filing

1. Compute from the law (article 150 VH bis CGI; BNC article 92 CGI for reward income).
2. Substantiate with the dated BOFiP in force for the filing year (quote BOI-…-YYYYMMDD).
3. Use the right branch: PVBMC-30 for disposals; BNC doctrine for reward income/professional.
4. Reconcile Form 2086 to both the law and the doctrine.
5. In an audit, the dated BOFiP version supports your year's position — keep the reference you relied on.

How vendor tools relate to the doctrine

Waltio (French-specialised) and Koinly implement the 150 VH bis method the BOFiP describes; they do not replace citing the dated doctrine in a dispute. Confirm the tool's method matches the current PVBMC-30 doctrine and the 2026 rate (31.4%) — the tool is the computation, the dated BOFiP is the substantiation.

How Wag3s helps

Wag3s Folio computes the 150 VH bis method consistent with the BOI-RPPM-PVBMC-30 doctrine and the 2026 PFU 31.4%, and separates reward income (BNC branch) from disposals (PVBMC branch) so the right doctrine applies to each — producing a Form 2086 that reconciles to both law and doctrine. See the Folio product page.

Further reading

• France Crypto Tax Guide 2026
• Cerfa 2086 Explained
• Crypto Capital Gains Calculation France (150 VH bis)
• PFU vs Barème: Choosing in France
• BNC vs PFU for Crypto in France
• DGFiP Crypto Tax Audit

Sources

• BOFiP-Impôts — BOI-RPPM-PVBMC-30 series (digital-asset disposals) (consult the current dated version)
• Article 150 VH bis CGI — Légifrance
• Loi de Finances 2026 — end of the irrevocability of the progressive-scale (barème) option; PFU 31.4% (CSG 9.2%→10.6%)
• Loi de Finances 2022 — professional crypto trading moved to BNC (article 92 CGI)