Moving from the United Kingdom to France does not end the United Kingdom tax administration’s interest in rent from a property that remains in the UK. A letting agent, or sometimes the tenant, may start withholding basic-rate tax under the Non-Resident Landlord Scheme. At the same time, a new French tax resident normally has to report foreign-source income in France and apply the France–UK double taxation convention. These are related questions, but they are not the same question: NRL withholding is a United Kingdom collection mechanism, while French reporting and treaty relief determine how the income is treated in the country where you now live.

This guide is for an individual British owner who lets a UK property after moving to France. It explains what triggers the withholding, how form NRL1 can authorise payment of rent without deduction, how a French declaration no. 2047 (the French foreign-income return) fits into the analysis, and which refund or challenge route matches the problem. It does not cover buying a property in France, setting up a company, or using a French société civile immobilière (SCI, a civil property-holding company). The decisive evidence is usually practical: your actual residence, the dates of the move, the letting agent’s certificates, the tax returns filed in both countries, and the wording of the notices you received.

I. Why is UK tax withheld when I move to France, and which country taxes the rent?

A. What triggers the UK Non-Resident Landlord Scheme and how does NRL1 stop gross-rent withholding?

The first distinction is between the property and the person. A dwelling situated in England, Wales, Scotland or Northern Ireland remains connected with the UK tax system because the rent arises from land in the United Kingdom. Your move to France changes your personal residence and may change the way you account for the income, but it does not turn the rent into French-source rent. HM Revenue and Customs (HMRC) describes the basic rule in its guide on UK rental income when the landlord lives abroad: rent from UK property remains taxable in the UK, and a person living abroad for six months or more per year is treated in that guide as a non-resident landlord even if that person remains UK-resident for UK tax purposes. That public description should be applied to the facts of the individual case, including any split-year or treaty residence position.

The Non-Resident Landlord Scheme is principally a withholding and reporting system. If the scheme applies and HMRC has not authorised gross payment, the letting agent normally deducts basic-rate tax from rent before paying you. If there is no agent, the tenant may have to deduct tax where the conditions stated by HMRC are met. The amount withheld is not automatically the final amount of tax that you owe. It is a payment on account which can be excessive where the property has allowable expenses, a loss, unused allowances, or another feature of your Self Assessment calculation. The agent should give you a certificate showing the rent and the tax deducted for the tax year. Keep the certificate with the bank statements and the underlying property accounts.

Form NRL1 is the individual application to receive UK rent without the usual deduction. HMRC’s current guidance states: Use form NRL1 if you are an individual non-resident landlord who wants to apply to receive UK rental income with no UK tax deducted. The wording matters. NRL1 is not an exemption from UK tax, not a decision that France is your only country of residence, and not a substitute for a UK tax return. It is an authorisation to receive the rent gross while you account for the liability through Self Assessment if HMRC requires you to do so. The same HMRC page is the correct starting point for the NRL1 application and approval process.

Your application should identify your principal residential address. HMRC asks for the Unique Taxpayer Reference (UTR), if known, your National Insurance number, if you have one, and the letting agent’s reference where relevant. That makes the application a residence and compliance file, not simply a request for a different payment method. Before sending it, compare the address and departure date with your French residence documents, the date on your tenancy or management agreement, and any UK return already filed. An unexplained mismatch can create a request for further information or a refusal, even when the underlying rental activity is genuine.

The online NRL1 service is available to an individual who can sign in. HMRC also provides a print-and-post route: complete the form, sign it yourself, and post it to the address shown on the form. If you want an adviser to act for you, the authorisation arrangements are separate. The notice of approval is sent to you or your authorised tax agent, and separate notices go to the letting agent or named tenants. Those notices state the approval reference and the date from which rent may be paid without deduction; HMRC says that date will usually be the first day of the quarter in which it received the application. Give the agent the notice rather than relying on a promise that the application has been submitted.

HMRC normally approves a complete and correct application when it is satisfied that you will comply with UK tax obligations. It can later ask for more information and can withdraw approval. A history of late returns or unpaid UK tax therefore matters even if the new application is factually correct. If HMRC refuses the application, read the notice carefully: the current guidance says that an appeal should be made in writing within 90 days of the date of the notice, with an independent appeal tribunal available if agreement cannot be reached. Record the date of receipt, the date of dispatch, and proof of delivery. Missing the appeal period is a separate procedural problem from proving that the withholding was excessive.

There is also a boundary around the present guide. HMRC has different forms for companies and trusts. If a company, trust or partnership is the recipient of the rent, the tax classification, treaty analysis and evidence may be different. Moving a personally owned property into an entity is not a simple NRL1 solution and raises matters outside this British personal desk. The question here is narrower: an individual owns the UK property, moves to France, and needs to control a withholding mechanism without confusing it with the final tax calculation.

B. How does the UK–France tax treaty interact with French tax residence and form 2047?

French tax residence must be determined before the cross-border return is prepared. Under Article 4 A of the French General Tax Code (Code général des impôts, or CGI), the domestic starting point is that people whose tax domicile is in France are liable to income tax on all their income. The official wording begins: Les personnes qui ont en France leur domicile fiscal sont passibles de l’impôt sur le revenu en raison de l’ensemble de leurs revenus. In practical terms, a French tax resident cannot leave UK rent out of the French return merely because the property and the first tax collection occurred in Britain.

Article 4 B CGI gives the domestic indicators: the household or principal stay in France, a professional activity in France, or the centre of economic interests in France. It also expressly preserves the effect of an international tax convention. A British citizen may therefore satisfy a domestic French criterion while a treaty tie-breaker still has to be examined if the UK asserts residence as well. The residence question cannot be answered simply by counting days or by pointing to a Withdrawal Agreement residence card. Keep the move chronology, household facts, work arrangements, and financial centre in one coherent file.

The 2008 France–UK convention allocates taxing rights over property income. Article 6 of the convention uses the direct rule: Income derived from immovable property (including income from agriculture or forestry) situated in a Contracting State may be taxed in that State. The same provision is available in the current UK government publication of the treaty text and in the French official publication on Légifrance. A UK rental property is therefore a classic source-state item for UK tax purposes. The article does not mean that the owner can ignore France: the residence state still applies its domestic reporting rules and the convention’s double-tax mechanism.

For the French return, start with the official DGFiP guidance on foreign-source income and the relevant form no. 2047 page. The French tax administration’s 2026 notice explains that a person domiciled in France who receives foreign-source income or collects income abroad must complete a 2047, then carry the amounts to the appropriate 2042, 2042-C or 2042-C PRO return. It expressly includes income from immovable property situated abroad. The amount has to be converted into euros according to the applicable rules. Keep the exchange-rate source, payment dates and bank evidence; a rounded annual figure that cannot be reconstructed is a poor answer to a later query.

The treaty method is more important than the label “foreign tax paid”. France’s official 2026 notice for form 2047 explains that a convention can eliminate double taxation by a credit or by exemption with the income retained for the effective rate. It also warns that foreign tax paid in accordance with the convention is not deducted from the income itself. The correct treatment depends on the nature of the income, the country table and the treaty article; do not subtract UK withholding from gross rent simply because the money never reached your bank account. The withholding certificate proves a UK collection event. It does not by itself determine the French taxable amount or the amount of treaty credit.

For the overall French reporting sequence, read this narrower NRL1 analysis together with the existing guide to UK rental income in France after Brexit. That broader article covers the general tax forms and social-charge framework; the present article adds the separate UK withholding, approval and repayment pathway. The link is a hub reference, not a reason to repeat the same subject: the practical question here is why rent was withheld and how to recover or prevent that specific deduction.

Article 24 of the convention is especially important for a French resident with UK-source income. In the French case, income that may be taxed or is taxable only in the UK is taken into account for the computation of French tax, subject to the treaty method. The UK tax is not deducted from that income. For income within Article 24(3)(a)(i), the credit is tied to the amount of French tax attributable to the income, provided that the French resident is subject to UK tax in respect of it. The treaty contains further limits and a separate rule for income in the categories listed in Article 24(3)(a)(ii). Link the working papers to the official Article 24 text, rather than importing a rule from a different treaty.

The Conseil d’État’s opinion of 12 February 2020, no. 435907, is a precise warning about that condition. In Conseil d’État, 9th–10th chambers reunited, 12 February 2020, no. 435907, the court explained that the income must be included in the UK tax base, sans que le résident de France en soit exonéré à raison de son statut ou de son activité, without requiring that an effective amount of UK income tax was actually paid. That opinion concerned the interpretation of Article 24 and British-source income; it is not permission to claim a credit without classifying the rent and documenting the UK reporting position. Its practical lesson is to preserve evidence that the income was declared or included in the relevant UK tax base, even where allowances or expenses reduce the UK liability to nil.

Finally, separate the NRL1 question from the treaty question. NRL1 asks HMRC whether rent can be paid without deduction while you report it through the UK system. Article 24 asks how the two countries remove double taxation once the income is classified and reported. You may need NRL1 and still owe UK tax; you may need a French 2047 even when a treaty credit removes or reduces French tax; and a tax withheld under NRL can be refundable in the UK without changing the French reporting obligation.

II. How do I recover tax already withheld and correct a French declaration?

A. How do I apply for NRL1, file Self Assessment or R43, and build the refund evidence?

Choose the UK procedure from the event that needs correcting. If rent is still being paid net of withholding, apply for NRL1 as soon as the residence and compliance facts are ready. If tax has already been withheld, the application may stop or reduce future deductions but does not, by itself, calculate a refund for earlier months. Earlier deductions have to be reconciled in the UK return or through the specific repayment route that applies to you. Treat the dates separately: the date you moved, the date the NRL scheme began, the date NRL1 was received, the date of HMRC approval, and the tax year covered by the certificate.

The evidence pack should begin with the letting agent’s annual certificate and a month-by-month schedule. Match the gross rent to the tenancy agreement, the agent’s statements and the bank credits. Identify repairs, management fees, insurance, finance costs and other amounts by category rather than presenting a single unexplained net number. Some costs may be restricted or treated differently under the UK rules, and French deductibility is not a substitute for UK deductibility. The working paper should show the figure reported to HMRC, the tax deducted under the NRL scheme, the tax ultimately due, and the difference claimed back.

Where HMRC requires Self Assessment, the public HMRC rental-income guide says that the residence section and property section must be completed. It identifies SA109 for residence and SA105 for property where a paper return is used, while online filing may require approved commercial software or an adviser because the ordinary HMRC online service is not available for this non-resident landlord return. The public guide currently identifies 31 October as the earlier deadline for a return sent by post. Confirm the deadline for the relevant tax year rather than copying a date from an old form. A late return can produce a penalty even when the final tax is zero.

When an agent has deducted too much, the normal route is to report the rent and the deduction in the relevant UK tax return, allowing HMRC to reconcile the account. A different route may exist for a person whose rental income is below the UK Personal Allowance and whose agent or tenant deducted basic-rate tax. HMRC says that such a person can use form R43 to ask for a refund, but also says that the route is not available where the claimant is not eligible for a Personal Allowance. Eligibility for an allowance is fact-sensitive for a person living in France, so do not file R43 merely because the tax deducted looks large. First establish whether the allowance is available under UK domestic rules, the treaty and your nationality or residence circumstances.

The distinction between NRL1 and R43 is important in a common practical situation. Suppose your agent deducted basic-rate tax from twelve months of rent, while your allowable UK expenses and your Personal Allowance leave little or no UK income tax. NRL1 may prevent the same cash-flow problem next year, but it is not the repayment form for the prior year. R43 may be appropriate only if its conditions are met. Otherwise, the figures belong in Self Assessment, with the agent’s certificate used as evidence of tax already paid. Do not claim the same deduction both on R43 and on a Self Assessment return.

If NRL1 is refused, make the written appeal within the 90-day period stated in HMRC’s refusal notice. Address the reason given rather than repeating that you live in France. If the issue is an incomplete address, supply the principal residence evidence. If the issue is a late return or unpaid balance, show the filing, payment or agreed arrangement. If the issue is uncertainty about who receives the rent, provide the ownership and agency documents. A short indexed bundle is easier for HMRC to assess than a large set of unlabelled bank statements. Keep the proof of posting and the appeal copy.

For a property let through an agent, ask the agent to confirm in writing when it will stop deducting tax after receiving HMRC’s notice. The approval notice is directed to the named agent or tenant; it should not be assumed that a change of agent carries the authorisation automatically. If the property changes hands, the letting contract changes, or the owner’s residence changes again, reassess the application. The NRL scheme deals with payment administration, so a new fact can matter even if the underlying property has not changed.

Use a cross-border ledger with two currency columns. The UK ledger should be in pounds and identify the UK tax year. The French ledger should show the euro conversion used for the 2047 and 2042, the relevant French calendar year, and the treaty treatment. Record whether the UK amount is a withholding, an assessed liability, a repayment, or an amount carried forward. A later refund from HMRC can affect the evidence supporting a French credit or a previous return. If a French credit was calculated from tax “paid” and that UK tax is later refunded, revisit the French calculation rather than leaving an inconsistent file.

There is no safe shortcut based only on the amount that reached your French bank account. The withheld amount, the UK taxable profit, the French declared income and the treaty credit are four different numbers. A clear reconciliation makes it possible to see whether the problem is an NRL withholding error, a UK return error, a French reporting omission, or a genuine difference between the two countries’ tax bases.

B. How do I challenge a French tax bill, a missed 2047 or double taxation?

On the French side, begin by identifying the exact defect. It may be that the UK rent was omitted entirely from form 2047; reported in pounds instead of euros; reported as a net amount after subtracting UK tax; carried to the wrong section of the 2042; or reported correctly but without the treaty credit or effective-rate treatment that the convention requires. A tax notice may also contain an arithmetic or data-entry error unrelated to the legal allocation of taxing rights. The remedy, evidence and deadline depend on that distinction.

Article 170 CGI is the statutory declaration framework. It requires the income declaration and supports the administration’s ability to compare foreign information with the taxpayer’s French return. The form no. 2047 should be used for foreign-source income before the amount is carried to the return corresponding to its nature. The DGFiP correction guidance explains that an online filer can use the correction service during the period in which it is open. For the 2026 campaign, the official page states a service period from 29 July to 30 November 2026; future campaigns may use different dates.

If the online correction service is closed, use the secure messaging service in your French tax account or write to the service shown on the tax notice. The official DGFiP procedure for challenging an income-tax notice allows supporting documents to be attached through secure messaging and also accepts a paper complaint. State the tax year, notice number, French tax number, the income concerned, the calculation requested, and the precise treaty or domestic-law basis. Ask for a corrected assessment or a refund only after showing the calculation that leads to it.

French law calls the formal process a réclamation contentieuse, meaning a formal tax claim seeking correction of an assessment or recognition of a legal right. Article L. 190 of the Livre des procédures fiscales defines the relevant class of claims. Its opening list refers to Les réclamations relatives aux impôts, contributions, droits, taxes, redevances, soultes et pénalités de toute nature. In a UK-rent case, explain whether you seek relief for an omission, a calculation error, a missing treaty credit, or an amount paid without legal basis. A generic request to “remove double tax” does not identify the correction the tax office can make.

For income-tax claims other than local taxes, the current Article R.* 196-1 of the Livre des procédures fiscales is a key deadline provision. It states that, to be admissible, claims for taxes other than local direct taxes and related taxes must generally be filed by 31 December of the second year following the relevant assessment, payment or event. The article has been in force in its current version since 30 July 2026. Calculate the deadline from the actual notice or payment and verify whether a special rule applies; do not assume that the date of the UK refund restarts the French period.

The French claim does not normally suspend payment. DGFiP’s claim guidance and its notice-challenge page explain that a complaint must be accompanied by a request for a stay of payment if you want to defer the disputed amount, and that guarantees may be required above the applicable threshold. A complaint and a stay are separate requests. If the amount is due and you simply stop paying while sending a complaint, collection action and late-payment consequences may follow even if the legal argument is ultimately sound.

Two provisions should be checked where the omission or correction has created a balance. Article 1727 CGI concerns interest for late payment, while Article 1728 CGI addresses the increases associated with late or missing declarations. These provisions do not mean that every late 2047 produces the same penalty: the filing history, notice, formal notice and taxpayer conduct matter. Correct promptly, explain the reason for the error, and ask for remission where the facts support it; keep the delivery receipt.

Your French evidence bundle should be capable of being read without opening a second file. Include the UK tenancy agreement, completion or ownership evidence for the UK property, the agent’s statements, NRL certificates, NRL1 application and approval or refusal, UK tax returns, SA109 and SA105 where relevant, R43 if used, HMRC assessments and repayment statements, bank records, exchange-rate calculations, French 2047 and 2042 copies, French tax notices, and any certificate of tax residence. Add a one-page chronology. The chronology should mark the move to France, the start of the first French tax year, each UK withholding period, each filing date and each notice received.

The treaty itself also imposes an evidence discipline. Article 30 of the France–UK convention provides that a person claiming its benefits must give the relevant tax administration a declaration describing the income, a statement from the other tax administration confirming treaty residence where required, and other evidence that domestic law may demand. The official French treaty text should be read with the year and income category in mind. A certificate of French residence may support the treaty analysis, but it does not replace proof of the UK tax treatment of the rent.

If the two administrations continue to apply the convention inconsistently after domestic correction routes have been used, Article 26 provides a mutual agreement procedure (MAP). It is an authority-to-authority mechanism for taxation that is not in accordance with the treaty, not a first-line substitute for NRL1, Self Assessment, form R43, form 2047 or a French claim. The Article 26 text sets treaty time limits, including presentation within three years from the first notification of the action that produces non-conforming taxation, subject to the current treaty wording and procedural rules. Record the first notification precisely before considering a MAP.

The case law shows why the file must prove both residence and income classification. In Conseil d’État, 7th–8th sections reunited, 14 February 1979, no. 06961, a British national’s nationality and Crown pension did not, without probative documents, establish residence in the UK for the former France–UK convention. The convention and domestic provisions have changed, but the evidential warning remains useful: nationality is not a tax-residence certificate. In CAA Versailles, 6th chamber, 9 June 2011, no. 10VE01416, the court distinguished income from the direct exploitation or letting of a London property from financial gains arising from borrowing and swaps used to finance it. That older case concerned the former convention and a company, so it is not a plug-in answer for an individual landlord; its relevance is the need to show that the receipt is actually rental income covered by the property article.

Use the current English treaty publication, the HMRC guidance on being taxed twice, and the French 2047 notice as operational references, but preserve the primary legal links in your file. The treaty does not turn an NRL deduction into a French tax credit, and a French credit does not automatically cause HMRC to refund a withholding. The UK refund must be proved through the UK account; the French correction must be proved through the French return and notice; only then can the cross-border result be reconciled.

Conclusion

After moving to France, a British individual letting a UK property should handle four connected but separate tasks: establish the actual residence position, keep the UK rental reporting current, apply for NRL1 if future withholding is creating a cash-flow problem, and report the foreign income on the French form 2047 with the correct treaty method. If tax has already been withheld, use the agent’s certificate and the appropriate UK route—Self Assessment or R43 where its strict conditions are met. If the French return or notice is wrong, correct it promptly or file a documented réclamation contentieuse within the applicable period. The strongest file reconciles pounds and euros, gross rent and expenses, withholding and final liability, and every notice date in both countries.

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