Losses on digital assets: France, the European outlier

After a volatile 2025, many bitcoin holders are asking the wrong question. Holding an asset at a loss is not the same as realising a loss: investors who entered bitcoin in 2025 may be sitting on unrealised losses, but no tax loss exists without a disposal.

France remains an outlier. It does not allow losses on digital assets to be carried forward beyond the same tax year, whereas most other European and non-European jurisdictions, including the United Kingdom, Germany, Switzerland, the United States and the United Arab Emirates, allow losses to be carried forward or otherwise recognised, under jurisdiction-specific conditions and limitations.

Down markets expose a deeper flaw: tax systems remain largely transaction-based, while digital assets operate in continuous, programmable environments.

It is time to rethink how tax is designed for digital assets.