French taxation of RWA

The law as it stands on 1 November 2026, after the social security financing act and the finance act for 2026, while the finance bill for 2027 is being debated in Parliament. Taxation changes every year, and this chapter will be revised after each finance act.

One simple idea is enough. The taxation of a token is that of the right it represents. In the absence of a tax category specific to RWA, a tokenised share is taxed as a share, a tokenised bond as a bond, a tokenised fund unit as a fund unit. The specific digital asset regime applies only to crypto-assets that are not financial instruments, first among them the stablecoins used as the cash leg. This rule, which follows from the definition of digital assets in the Monetary and Financial Code, avoids a great deal of confusion.

It has a decisive practical consequence for the entrepreneur. The choice of the token’s legal form, share, bond or fund unit, determines the taxation of its investors, and therefore the appeal of the product. Legal structuring and tax structuring are designed together.