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 article is the reference map: which official doctrine governs French crypto tax, what is binding versus interpretive, and the one change that matters for 2026, namely that the barème option is no longer irrevocable. It is the doctrine layer beneath the 2086 form and the 150 VH bis calculation; the France crypto tax guide is the starting point.

The doctrine at a glance

• The main doctrine is BOI-RPPM-PVBMC-30 (occasional-investor digital-asset disposals), with sub-references -30-10/-20/-30.
• BOFiP is opposable administrative doctrine, reliable as published, but the binding law is the CGI (article 150 VH bis).
• The 2026 change: the Loi de Finances 2026 ended the irrevocability of the progressive-scale (barème) option, making it a year-by-year choice.
• The PFU is 31.4% (CSG on capital income 9.2% to 10.6%); the 150 VH bis method and the €305 threshold are unchanged.
• The doctrine is split by activity: disposals sit in the PVBMC branch, reward income and professional trading in the BNC branch (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.

Where a tool relates to the doctrine

Waltio (built for the French market) 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.

Navigating the Doctrine in Practice: 2026 Filing Points

The 2026 filing year introduces two concrete BOFiP-adjacent issues that practitioners should be aware of beyond the headline barème-option change.

The Rate Change and Form 2086 Consistency

The 2026 PFU rate of 31.4% derives from the CSG increase on capital income (9.2% → 10.6%) that took effect. The BOFiP doctrine covering the computation under article 150 VH bis references the rate structure, and any dated BOFiP reference you cite should be from a version that reflects the post-increase rate. A Form 2086 correctly computing the 150 VH bis gain/loss but then carrying the result forward with a 30% rate is wrong for 2026 disposals. The law controls the rate; the BOFiP gives the application context.

The Barème Option in the 2026 Return

The removal of the irrevocability of the barème election has a practical workflow implication: filers (and their advisers) can now run the PFU vs barème calculation each year and choose the better outcome without being locked in. For the 2026 return (income year 2025 disposals) and for the 2027 return (income year 2026 disposals), the decision should be made fresh.

The choice depends on the taxpayer's marginal income-tax bracket. A holder in the 11% bracket who has no other capital income will generally prefer the barème — the progressive rate on the capital gain is lower than 12.8%. A holder in the 30%+ bracket will generally prefer the PFU flat rate. The BNC activity (staking, mining) is taxed as professional or non-commercial income under the BNC doctrine regardless of this election; only the disposal-side gains (PVBMC branch) are subject to the PFU vs barème choice.

DeFi and the Doctrine's Current Limits

The BOI-RPPM-PVBMC-30 series covers occasional-investor disposals against fiat or goods and services. Newer DeFi activity — liquidity provision to automated market makers, yield-bearing vault deposits, token wrapping — sits in a zone where the existing doctrine is silent or sparse. The DGFiP has not issued comprehensive BOFiP guidance on these activity types as of mid-2026. The practical posture is: apply the closest analogous published doctrine, document the reasoning, and acknowledge uncertainty in the client file. An undocumented DeFi position is more exposed than one that took a reasoned, documented stance citing the applicable partial doctrine.

Using the Dated Reference in an Audit

When a DGFiP control arises, the relevant BOFiP version is the one in force for the year under review. Always cite the dated identifier format (BOI-RPPM-PVBMC-30-30-YYYYMMDD) in internal memoranda, not an undated "per BOFiP." The bofip.impots.gouv.fr search returns historical versions — preserve the version you relied on, because the administration updated the doctrine and a later version may differ.

Comparing France to Neighboring EU Jurisdictions

France's combined approach — PFU flat rate + a specific computation method (150 VH bis) + a dedicated form (2086) + the BOFiP doctrine as the interpretive layer — is more structured than most EU peers:

• Germany: crypto taxed under personal income (progressive), exempt after one year — no equivalent to the 150 VH bis portfolio method; gains computed per lot.
• Belgium: no specific crypto capital-gains tax for private investors as private management; no equivalent dedicated form.
• Luxembourg: six-month holding exemption; no equivalent 150 VH bis portfolio aggregation.
• Netherlands: a wealth-tax (box 3) approach based on an imputed return on notional wealth, not per-disposal capital gains.

The structured French approach — with an explicit method and BOFiP documentation — creates a clearer audit defense trail than simpler or less-documented regimes, at the cost of greater complexity in the computation.

Where Wag3s fits

Wag3s Folio computes the 150 VH bis method consistent with the BOI-RPPM-PVBMC-30 doctrine and the 2026 PFU at 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. Reading the dated doctrine into a contested position, and the PFU-versus-barème election now that it is reversible, is an expert-comptable's judgement; Wag3s produces the computation that judgement substantiates. 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 — RPPM, cession d'actifs numériques à titre occasionnel (BOI-RPPM-PVBMC-30) and the modalités d'imposition et obligations déclaratives sub-reference BOI-RPPM-PVBMC-30-30 — consult the current dated version.
• Légifrance — Article 150 VH bis CGI: the binding occasional-investor regime the doctrine applies.
• Légifrance — Article 92 CGI: the BNC branch for reward income and professional trading.
• Loi de Finances 2026 — end of the irrevocability of the progressive-scale (barème) option; PFU 31.4% (CSG 9.2% to 10.6%).
• Loi de Finances 2022 — professional crypto trading moved to BNC (article 92 CGI).