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Under French tax law, a taxable event arises when you dispose of digital assets for consideration—including when you convert crypto into fiat or pay for a good or service with crypto. For individuals in the ordinary regime, that gain is generally taxed at a global flat rate of 30% (12.8% income tax + 17.2% social levies), with an annual €305 de minimis threshold for small disposals. Crypto-to-crypto swaps without cash (“sans soulte”) are not taxed at that moment. Bofip
Saint-Barthélemy, by contrast, is a collectivité d’outre-mer with autonomous taxing power since 2007 and—since 2012—a PTOM (overseas country and territory) outside the EU customs territory. It sets its own taxes within the framework of French organic law and an inter-governmental convention to prevent double taxation and combat evasion. Put simply: France and Saint-Barth are distinct tax spheres, even though both sit under the French flag. Sénat+3Douane.gouv.fr+3Légifrance+3
Crucially, who is a Saint-Barth tax resident? For individuals, the organic law requires five years of residence before the local administration can treat you as tax-resident of the island; similar tests exist for legal entities via local substance and effective management rules. Residency is not a marketing claim—it is a legal status that must be earned and evidenced. Légifrance+1
Takeaway: in metropolitan France, converting crypto to euros for a purchase (e.g., real estate) is ordinarily taxable at 30% for individuals. In Saint-Barth, tax neutrality may be available if your company and conversion are genuinely within the island’s tax sphere and you meet residency/substance conditions. Le modèle fiscal de Saint-Barthélemy permet une neutralité légale unique au monde.
Before comparing regimes, align on terms used by tax authorities and notaries:
Digital-asset disposal (France). The French tax administration treats a sale for euros or a purchase of goods/services with crypto as a disposal for consideration. Individuals’ gains are calculated on each taxable disposal using the global wallet method (value of the portfolio and capital initial), and reported on the French return with a dedicated annex. Crypto-to-crypto exchanges without cash benefit from deferral at the time of exchange. Bottom line: fiat conversion = taxable, pure crypto swaps = not taxable at that moment. Bofip
Saint-Barth’s fiscal autonomy. The island sets its own contributions and tax rules under the Code général des collectivités territoriales (CGCT). The organic law and subsequent instruments also require State–Collectivity conventions on taxation to prevent double taxation and coordinate enforcement. Since 2012, the island’s PTOM status confirms a separate external regime (notably customs), reinforcing the idea that transactions carried out within Saint-Barth’s legal, banking and corporate perimeter can be assessed under local law rather than mainland French tax. Légifrance+2Légifrance+2
Residency & substance. For individuals, the five-year rule is explicit in LO 6214-4 CGCT. For companies, effective management, local governance (board/manager on island), and real economic substance (office, accounting, local bank account) are decisive signals. In practice, banks and notaries will look for documentary anchors proving that decisions and flows occur on island. Légifrance+1
Key comparison lens for conversions:
Analogy: think of France and Saint-Barth as two neighboring harbors with different port fees. Your tax bill depends on which harbor you actually dock in, not which flag flutters on the stern.
1) The French taxable trigger is simple—and unforgiving.
Convert crypto into euros in your own name while a French tax resident, and the gain is ordinarily taxed at the PFU 30% rate (12.8% + 17.2%). Use crypto to pay a vendor? Same result: a taxable disposal. Crypto-to-crypto without cash remains non-taxed at that moment, but the later fiat exit will crystallize the gain. Documentation (portfolio value, cost basis, annex data) is required. Bofip
2) Misunderstanding Saint-Barth’s autonomy.
Saint-Barth is not a “tax trick”; it is a lawful, autonomous tax territory within the French Republic. The organic law allocates taxing powers to the island and requires a State–Collectivity convention precisely to prevent double taxation and evasion. Attempting to claim island benefits without meeting residency/effective-management tests invites reclassification and back-tax. Légifrance+1
3) The five-year reality check.
For individuals, LO 6214-4 explicitly requires five years of residence before being treated as Saint-Barth tax resident. Short-term movers who convert large crypto positions may still be viewed as French residents for tax purposes, exposing conversions to PFU. Plan sequencing: residency first, conversions next. Légifrance
4) Corporate mis-footing.
Buying personally and wiring from an off-island personal account complicates the file. By contrast, a Saint-Barth single-asset company with local management (gérance locale), registered office, accounting, and a local bank account creates a coherent substance narrative. La gérance locale garantit la résidence fiscale de la société et la conformité internationale.
5) Reporting symmetry.
Even if local law treats conversions favorably, global transparency (France/EU/OECD) means your books must match what authorities and platforms will report. France’s guidance details what must be declared on the annex; ignoring those data points in your internal ledgers risks mismatch queries and bank holds. Bofip
6) Notarial AML in France.
French notaries are public officers with stringent AML duties. If euros arise from a documented, on-island corporate perimeter with clean travel-rule and source-of-funds, the closing is smoother. If not, expect additional verification and potential escrow delays.
Metaphor: conversions are like customs corridors. If you walk the green lane (residency, substance, paper), you exit quickly. Take a shortcut, and the red lane opens—interviews, unpacking, and sometimes a return flight.
A) In mainland France (individual scenario).
If you remain a French tax resident, model the PFU 30% impact before converting, and verify whether any BNC/BIC professional qualification applies (frequent trading/mining may trigger non-PFU regimes). If the plan is to acquire French real estate, prepare the BOFiP annex data (portfolio value, capital initial, etc.) so your notary and bank can reconcile figures. Crypto-to-crypto defers the tax point, but fiat landing will crystallize it. Bofip
B) In Saint-Barth (individual residency).
Pursue genuine residency: physical presence, five-year rule, local ties—then review local law for how disposals are treated. The island’s fiscal autonomy allows it to set its own rules; what matters is that your facts (home, time, economic interests) align with island residency. Until residency is established, assume French rules still bite. Légifrance+1
C) In Saint-Barth (corporate vehicle).
Create a Saint-Barth single-asset company (registered office, accounting, local bank account) with on-island gérance to establish effective management locally. Execute the crypto-to-euro conversion via regulated rails into the company’s local account and acquire the property through that entity. This concentrates flows on island and aligns with notarial AML and substance expectations. (Chez SBH Capital Partners, nous aidons nos clients à transformer leurs actifs numériques en patrimoine tangible.)
D) Preventing double taxation.
The organic framework provides for a State–Collectivity convention to prevent double taxation and coordinate assistance. The practical rule is simple: don’t straddle two systems. Choose one tax sphere, build substance, and maintain documentary coherence (board minutes, travel-rule payloads, SWIFT receipts, notary funds-mapping memos). Sénat
E) Bank-first documentation.
Whichever route, curate a linear file:
Analogy: treat tax outcomes like architectural load paths. If your structural beams (residency, substance, banking) are correctly placed, the entire house stands, even in regulatory storms.
We deliver a full legal-banking corridor in Saint-Barth so your conversion lives where your acquisition and governance live.
1) Incorporation & management.
We create a 100% client-owned Saint-Barth company with registered office, local accounting, and a local bank account. We serve as gérant, holding boards on island, maintaining minutes and decision logs—concrete facts that support effective management in Saint-Barth. La gérance locale garantit la résidence fiscale de la société et la conformité internationale.
2) Conversion rails that pass institutional due diligence.
We pre-qualify regulated counterparties and ensure identity payloads (travel-rule) ride with every transfer. Funds land in the local company account ready for notarial escrow. Our internal checklists mirror the declarative fields that French guidance expects in a disposal context, ensuring interoperability if any cross-reference ever arises. Bofip
Discretion, compliance, and excellence in Saint-Barthélemy.
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