You live in France, your employment contract is with a company in London, and your office is the spare bedroom. Every morning you log on to British systems, attend British meetings and receive a salary paid in pounds into a British bank account, with British PAYE deducted at source. Many British remote workers assume that this means they remain British taxpayers only, with nothing to declare or pay in France. That assumption is expensive. Since Brexit, a British citizen living and working in France is a third-country national whose work is performed on French soil, and France taxes work performed in France while also claiming social contributions on it. Your employer, even with no office in France, picks up French obligations too, from payroll registration to accident cover and the paperwork that lets you work legally.

This guide answers the three questions every British remote worker asks: where do you pay income tax when the work is physically done in France, which social security system takes the contributions, and do you need a French work permit when your employer is British. It follows the French Tax Code (Code général des impôts, the general tax statute), the France–United Kingdom double tax treaty signed in London on 19 June 2008, the French Labour Code (Code du travail, the employment statute), the Social Security Code (Code de la sécurité sociale, the social protection statute) and the post-Brexit Trade and Cooperation Agreement, with court decisions quoted word for word. French terms are explained as they appear.

I. Where do you pay income tax when your British job is done from France?

A. Are you a French tax resident once you live and telework in France?

French tax residence, the domicile fiscal, decides whether France taxes your worldwide income or only your French-source income. Article 4 A of the Code général des impôts, the general tax statute, states the principle: “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.” A person whose tax home is in France pays French income tax on all of their income, wherever it comes from. A British salary paid by a London employer therefore falls inside French tax if you are a French tax resident.

Three alternative tests lead to French tax residence, and meeting any one of them is enough. Article 4 B of the Code général des impôts provides that persons “ayant leur domicile fiscal en France au sens de l’article 4 A” include “Les personnes qui ont en France leur foyer ou le lieu de leur séjour principal”, “Celles qui exercent en France une activité professionnelle” otherwise than on a merely accessory basis, and “Celles qui ont en France le centre de leurs intérêts économiques”.

A British remote worker who rents or owns a home in France, whose partner or children live there, and who performs the job day after day from that home will normally meet the first test, the foyer (the permanent family home), and the second test as well, since the salaried activity is exercised in France and is plainly not ancillary. The administrative court of appeal of Paris recalled these very provisions in a recent tax-residence dispute, CAA Paris, 3 February 2023, No 22PA01495, quoting that persons are deemed to have their tax domicile in France where they have “leur foyer ou le lieu de leur séjour principal”, where they carry on a professional activity in France unless it is merely accessory, or where they have the centre of their economic interests. In that case the taxpayer argued that his home and working life were in China, yet the court kept the French assessments and granted only one relief: “Article 1er : M. B… est déchargé de la pénalité de 80 % qui lui a été infligée sur le fondement du c) du 1. de l’article 1728 du code général des impôts au titre des années 2015 à 2016.” The rest of the claim was dismissed: “Le surplus des conclusions de la requête de M. B… est rejeté.” The lesson is practical. Courts test where you actually live and work, not where your employer sits or where your salary lands, and they enforce the resulting tax with penalties unless you can show genuine good faith.

Where both countries claim you, the treaty breaks the tie. Article 4 of the France–United Kingdom convention of 19 June 2008, the treaty text published by the French tax administration, first confirms that a resident means anyone liable to tax by reason of domicile, residence, place of management or any similar criterion. It then settles dual residence for individuals step by step: first the State of the permanent home, then, where each State hosts one, the State of the closest personal and economic ties, known as the centre of vital interests, and only afterwards habitual presence and nationality. For the typical remote worker settled in France with a permanent home there, the tie-breaker points to France, and the familiar days-counting refrain that fewer than 183 days means safety has no footing at this stage. That figure belongs to a different article, examined next, and it does not decide residence.

Our earlier analysis of how British couples prove tax residence after Brexit, with its evidence checklists for homes, travel records and economic ties, remains a useful companion to this section: British Couples Split Between France and the UK: How to Prove Tax Residence After Brexit.

B. Which country taxes your UK salary when the work is physically done in France?

Once France counts you as a resident, the treaty allocates the right to tax your pay. Employment income is governed by Article 15, headed “Revenus d’emploi”, of the France–United Kingdom convention of 19 June 2008. Its first paragraph keeps taxing rights in the worker’s home State unless the employment is exercised in the other State, in which case that other State may tax the corresponding pay. In plain terms, a French resident working from home in France exercises the employment in France, so France may tax the corresponding pay even though the employer is British and the money is paid in London. The place of performance decides, not the employer’s address, the currency or the payroll system.

The second paragraph is the famous 183-day exception, and it is narrower than its reputation. It provides that pay for work done in the other State stays taxable only in the residence State if three cumulative conditions are all met: presence in the work State for no more than 183 days in any twelve-month period, payment by or on behalf of an employer who is not resident in that State, and no bearing of the cost by a local permanent establishment, the établissement stable (a fixed place through which the employer’s business is wholly or partly carried on). For a French resident whose employment is exercised in France, this exception simply does not open, because the work is not exercised “in the other State” at all. It can only help in the mirror situation — for example a British resident sent to France for a short assignment — or for apportioning a genuinely split role, where the days actually worked in each country divide the salary between the two tax bases. A full-time remote worker living in France therefore owes French income tax on the full salary, plus the French social levies collected with it, and British PAYE deducted in London is a credit problem, not an exemption.

That strict reading is consistent with how the French courts handle this treaty. In Conseil d’Etat, 5 February 2021, No 430594, the highest administrative court examined “l’article 13 de la convention fiscale franco-britannique du 19 juin 2008” in a dispute about royalties collected through a British society, testing whether the recipient was the true beneficial owner rather than a mere intermediary. The court upheld a substance-over-form approach to treaty benefits. Remote workers should draw the practical moral. Routing pay through a continuing British payroll, keeping a British employment contract, or staying on British payroll software does not move the place of work. What counts is where the hands type and the calls are taken, and a French auditor will ask for lease agreements, utility bills, travel logs and connection records before accepting any other story.

In practice, declare the worldwide salary in France each spring on the standard return and its foreign-income supplement, keep the British P60 and payslips, and reconcile the British tax already withheld so double taxation is relieved through the treaty credit mechanism rather than paid twice. Employees who split genuine working days between London and France should keep a contemporaneous day-count diary, because only the documented British workdays can support excluding part of the pay from the French base. If the assessment looks wrong — wrong apportionment, denied credit, or penalties for a first filing made in good faith — challenge it through a formal claim, the réclamation contentieuse (the written complaint to the tax office), then before the administrative tribunal and, on appeal, the administrative court of appeal. The CAA Paris decision quoted above shows both sides of that litigation: residence findings are hard to overturn, but penalties can fall where good faith is shown, which is why filing on time with full disclosure is the cheapest protection available.

II. Which social security system covers you and do you need a French work permit?

A. Do you pay French social charges on remote work for a British company?

Income tax is only half the bill. French social contributions, the cotisations sociales (compulsory levies funding health, pensions, family benefits and work-accident cover), attach to salaried work performed in France regardless of the employer’s nationality. Article L311-2 of the Code de la sécurité sociale states the rule in sweeping terms: “Sont affiliées obligatoirement aux assurances sociales du régime général, quel que soit leur âge et même si elles sont titulaires d’une pension, toutes les personnes quelle que soit leur nationalité, de l’un ou de l’autre sexe, salariées ou travaillant à quelque titre ou en quelque lieu que ce soit, pour un ou plusieurs employeurs et quels que soient le montant et la nature de leur rémunération, la forme, la nature ou la validité de leur contrat ou la nature de leur statut”. A British citizen working as an employee from a home in Lyon or Bordeaux is therefore compulsorily covered by the French general scheme, and the contributions must be collected in France. Before Brexit the European coordination regulations allocated that coverage automatically; since 2021 the mechanism is the social security protocol to the EU–United Kingdom Trade and Cooperation Agreement. The French liaison body, the CLEISS (the centre for European and international social security liaison), explains that the second post-Brexit instrument is the Trade and Cooperation Agreement with its social security protocol signed on 30 December 2020, which carries over the European architecture of equal treatment, aggregation of insurance periods, a single applicable legislation and export of benefits. One legislation only, equal treatment, aggregation of insurance periods and export of benefits — but the applicable legislation for genuine remote work from France is French, as the CLEISS pages for employers sending staff between Britain and France confirm case by case. Source: CLEISS, FAQ Brexit.

The Court of Cassation has repeatedly enforced that single-legislation logic. In Cass. 2nd civil chamber, 5 January 2023, No 21-13.487, a dispute about which country’s fund could claim contributions, the coordination rule at the heart of the case was recalled in these terms: “« a) la personne qui exerce une activité salariée sur le territoire d’un État membre est soumise à la législation de cet État, même si elle réside sur le territoire d’un autre État membre ou si l’entreprise ou l’employeur qui l’occupe a son siège ou son domicile sur le territoire d’un autre État membre »”. The work State takes the contributions even where the employer sits abroad. The protocol now carries that same work-State principle into the Franco-British relationship, so a London employer cannot keep a France-based remote worker on British National Insurance indefinitely as if Brexit had changed nothing.

Where work straddles both countries, procedure matters as much as principle. In Cass. 2nd civil chamber, 30 November 2023, No 21-18.251, a self-employed worker in France invoked a salaried activity in Portugal to escape French arrears, and the Court of Cassation quashed the appeal ruling for skipping the mandatory coordination step, holding that the court below should have forced the fund to run the multi-state determination procedure and waited: “il lui appartenait d’inviter la caisse à mettre en oeuvre la procédure prévue par l’article 16 du règlement n° 987/2009 et, dans cette attente, de surseoir à statuer”. For British remote workers who genuinely split activity — some weeks in London, some in France — the equivalent lesson is to get the applicable-legislation decision from the designated institution at the place of residence before the funds on either side issue demands, and to keep the resulting certificate with the payslips. Without that paper, both systems may bill at once and each will claim it acted correctly.

For the employer, the consequence is concrete. A British company with staff habitually working in France must register as a foreign employer without a French establishment and run French payroll, with URSSAF (the network of agencies collecting social contributions) as the collection body, or face a reassessment, the redressement (an upward correction of contributions after audit), plus surcharges. French cover also brings French protection. In CA Amiens, 2nd social protection chamber, 8 April 2026, RG 25/02765, an employer that had declared a fatal home incident with the words “M. [Y] [L] était en télétravail cette journée là ‘ décès du salarié ce jour-là (circonstances inconnues)” then entered reservations, arguing nothing proved the death happened at the telework place or in the course of work, lost before the fund and on appeal: the court confirmed the take-over as a work accident, an accident du travail (an injury or death occurring by the fact or on the occasion of work, which opens specific compensation rights), ordering the employer to bear the appeal costs and “déboute la SARL [1] de sa demande d’inopposabilité de la décision de prise en charge par la CPAM du Jura de l’accident du travail”. Remote work from France therefore means French accident cover, French occupational risk, and a British employer answering to a French health fund, the CPAM (the local health insurance fund). Anyone negotiating a transatlantic telework clause should fix in writing the declared place of work, working hours, equipment, right to disconnect and accident-reporting steps, because after an incident those lines decide which fund pays and who is liable.

B. Does a British citizen need a French work permit to telework from France?

Since the end of free movement, British citizens are third-country nationals in France, and working without the right papers exposes both sides. The public service guide states the employer’s duty bluntly: an employer wishing to hire a foreign worker in France must first obtain a work authorisation, subject to exceptions. Source: Service-Public, Autorisation de travail d’un salarié étranger en France. The Labour Code backs that duty with a verification obligation: Article L5221-8 of the Code du travail requires that “L’employeur s’assure auprès des administrations territorialement compétentes de l’existence du titre autorisant l’étranger à exercer une activité salariée” — the employer checks with the competent local authorities that the foreign worker holds a document authorising salaried activity. Employing a person without that authorisation is punished by administrative fines and, in serious cases, criminal penalties, and the worker risks refusal or withdrawal of the residence document, the titre de séjour (the permit authorising a foreigner to live in France).

Two situations must be distinguished. British residents protected by the Withdrawal Agreement, who hold the specific residence document issued under that treaty, keep the right to live and work in France on the strength of that document and do not need a separate work authorisation for the activity it covers. Everyone else — new arrivals since 2021, including the remote worker who moves to France to join a partner or enjoy a lower cost of living while keeping the London job — needs an immigration route that authorises both residence and the salaried activity performed in France. In practice the British employer files a work-authorisation request before the hire or the move, and the worker then applies for the matching visa and residence permit; the exact permit family depends on salary level, qualifications and whether the role is framed as a local hire, an intra-group arrangement or a talent route, so the file should be checked with the competent prefecture, the préfecture (the State authority in each département handling foreigners’ files), before signing a lease. Attempting the arrangement on a visitor’s 90-day stay is the classic trap: the short Schengen stay authorises presence, not work, and border and prefecture practice since the new entry-exit system treats repeated long remote-working stays without a proper permit as misuse. Our guide on overstays and border refusals details those controls for British visitors.

French law also frames the telework itself. Article L1222-9 of the Code du travail defines the arrangement: “le télétravail désigne toute forme d’organisation du travail dans laquelle un travail qui aurait également pu être exécuté dans les locaux de l’employeur est effectué par un salarié hors de ces locaux de façon volontaire en utilisant les technologies de l’information et de la communication.” Telework is voluntary work that could have been done on the employer’s premises but is performed elsewhere using information technology. The statute then allocates the employer’s duties — equipment, cost reimbursement, workload monitoring, accident prevention and reversibility — which apply in full where the teleworker’s home is in France, even if the employer’s human-resources team sits in London. A British contract that declares English law applicable does not displace the French public-order rules on working time, minimum wage, health and safety or termination where the work is habitually performed in France, and disputes about dismissal or unpaid overtime go to the French employment tribunal, the conseil de prud’hommes (the specialist court for employment disputes). Before moving, align the contract with French mandatory rules, register the payroll, and put the telework terms — place of work, equipment, expenses, monitoring tools and data rules — in a written amendment rather than an informal email exchange.

Conclusion

A British citizen teleworking full-time from France for a London employer lives under French tax, French social security and French employment public-order rules, however British the contract, the payroll and the bank account look. Residence follows the home and the daily work, the treaty taxes the salary where the employment is exercised, the Trade and Cooperation Agreement’s protocol keeps a single social legislation — here the French one — and the employer must register, contribute and verify the right to work. The compliant sequence runs in this order: secure the correct visa and residence document with work rights, obtain the work authorisation where one is required, register the British employer for French payroll, declare the worldwide salary in France while relieving British withholding through the treaty, and document any genuinely split UK–France working pattern day by day. Each step has its paper, each paper has its deadline, and the court decisions quoted above show that judges reward files built early and punish arrangements improvised after an audit, an accident or a dismissal. Where the pattern is split or the employer resists registering, take advice before the first payslip, not after the first reassessment.

Need a quick opinion on your case?

You work remotely from France for a British employer and wonder where your salary is taxed, which fund should take the contributions, or whether your papers allow it? Our cabinet offers a telephone consultation within 48 hours with a lawyer of the firm to review your situation and your next steps.

Call +33 6 46 60 58 22 or write through our contact page with a copy of your employment contract, your latest payslips and your current residence document, so the applicable tax, social security and immigration rules can be checked against your actual working pattern.