Moving to France after Brexit is not only a question of finding a home and arranging the removal van. A British national who intends to live in France must separate four questions that are often confused: the right to enter and stay, French tax residence, the taxation of UK income, and access to healthcare. The answer can also change during the year in which the move takes place.
The practical difficulty is greatest for a retiree or financially independent person. A UK State Pension, workplace pension, private pension, savings and a British bank account can all remain connected with the United Kingdom while the person’s legal and tax life moves to France. The France–UK Withdrawal Agreement protects some people who were already resident in France before 1 January 2021, but it is not a general residence route for someone moving now. The France–UK tax treaty can prevent the same pension from being taxed twice, but it does not remove the need to declare it or to establish which pension is being considered. Healthcare may be funded through an S1 form, through French activity or through the French residence system, depending on the facts.
This guide sets out a first-year sequence for a British reader: secure the correct residence route, identify the tax residence, classify each pension, organise healthcare, and preserve the evidence needed for a French tax return or a treaty claim.
I. Moving to France from the UK after Brexit: which residence and tax rules apply?
A. Do British citizens need a visa or residence permit for France after Brexit?
The first distinction is between a visit and a move. A British passport holder may visit the Schengen area for short stays under the applicable 90-days-in-any-180-day period. That permission is not a right to settle in France, work from France, or turn repeated visits into a permanent residence. The official France-Visas long-stay guidance states that, for a stay exceeding 90 days, an application for a long-stay visa must be made in advance, and that nationality does not by itself exempt the applicant from the requirement. Service-Public’s guidance on stays longer than three months expresses the same rule in French: a foreign national who wants to stay in France for more than three months must hold a long-stay visa or a residence permit.
The correct category depends on the project. A financially independent retiree may look at a visitor route. A person taking employment, running a permitted activity, joining a spouse, studying or moving with family members must examine a different route. A visitor permit is not a substitute for permission to work. The application should therefore describe the real purpose of the stay, the source of income, the accommodation, the health cover and the family situation. Using a visitor route while actually working or operating a business can create a residence and compliance problem that cannot be repaired by simply paying tax.
There is a separate regime for people protected by the Withdrawal Agreement. Article 3 of Decree no. 2020-1417 of 19 November 2020 identifies, in particular, British nationals who had exercised a right to reside in France before 1 January 2021 and continued to reside there afterwards. The operative text begins: « Les articles 5 à 33 du présent décret s’appliquent aux ressortissants étrangers relevant des situations suivantes ». It is a scope provision, not a new route for a British national who first decides to relocate to France in 2026.
For a person covered by that regime and resident in France for less than five years, Article 12 of the same decree provides a five-year document bearing the Withdrawal Agreement wording. The official Article 12 text states: « Ce titre a une durée de validité de cinq ans à dater de sa délivrance ». After five years of regular residence in the relevant circumstances, Article 21 provides for a ten-year permanent residence document. Its official text refers to a person who « a résidé en France pendant cinq années et y séjourne régulièrement ».
That distinction matters where a British family moved to France before Brexit but a spouse or child joined later. Article 3 covers certain family members, but the dates, family link, dependency and visa history have to be checked. A new spouse who has no protected status may need an ordinary family residence route. A British national who was already protected should keep the old application, residence evidence, permits, tax records and proof of continuity, especially if a permanent document or renewal is later requested.
For a new move, the documents normally begin with the passport and the chosen visa application. The applicant should also prepare proof of accommodation, sufficient resources, health insurance or evidence of the intended healthcare route, civil-status documents where relevant, and documents showing the source and regularity of pension income. Foreign documents may need an apostille, a certified translation or both. The exact list depends on the visa category and the consulate or prefecture handling the case.
A residence document and a tax residence are related but not identical. A person can hold a French residence permit while still being treaty-resident elsewhere for a period, and a person can become tax resident in France without having understood the immigration consequences. The permit should be maintained separately from the tax file. Keep copies of the application, the visa validation, the residence card, prefecture correspondence, passport stamps, tenancy or ownership evidence, utility records and travel dates.
The 90-day rule should also be treated as a warning sign. It measures permitted short-term presence; it does not decide the tax treaty tie-breaker and does not replace a long-stay visa. A person who spends most of the year in France, keeps a spouse or dependent family there, or moves the centre of daily life there may have created a French tax question even before the immigration file is complete.
B. When does a British newcomer become tax resident in France?
French domestic law begins with the concept of the French tax domicile, or domicile fiscal. Article 4 B of the French General Tax Code, the Code général des impôts, lists several independent connecting factors. The verified wording includes: « Les personnes qui ont en France leur foyer ou le lieu de leur séjour principal » and also refers to a professional activity or the centre of economic interests in France. The current Article 4 B text on Légifrance also makes clear that an international tax treaty can override the domestic result where the treaty assigns residence to the other state.
In practical terms, the foyer is the place where the person normally lives and where the family base is located. The séjour principal is the main place of stay. The economic-centre test looks at the most significant investments, income-producing activity and financial interests; it is not reduced to the country where a bank account happens to be open. Spending days is relevant, but a day count alone is not a complete answer.
The reasoning in Tribunal judiciaire de Paris, 29 April 2025, no. 22/06549 is a useful warning. The judgment states: « Le foyer s’entend du lieu où le contribuable habite normalement et a le centre de ses intérêts familiaux sans qu’il soit tenu compte des séjours effectués temporairement ailleurs ». The court examined the reality of the home, electricity use, mail, bank movements, insurance and other evidence rather than treating a foreign account or a declared foreign address as decisive. The case was not about a British retiree, but the evidential lesson is transferable.
The Court of cassation made the compliance point even more directly in Criminal Chamber, 13 March 2002, no. 01-82.170. It held that « le contribuable est tenu de déclarer les éléments du revenu global, y compris ceux qui, en vertu d’une convention internationale relative aux doubles impositions, sont susceptibles d’être exonérés ». In English: a treaty allocation does not authorise a person to omit income from the filing process. The pension may ultimately be taxed in one country, relieved by a credit, or included only for a rate calculation, but it still has to be identified correctly.
The France–UK tax treaty then provides a second stage. Article 4 of the Convention, published by Decree no. 2010-20 of 7 January 2010, defines treaty residence and supplies tie-breaker rules for a person resident under both domestic laws. The analysis moves through a permanent home, the centre of vital interests, habitual abode and nationality, with the competent authorities able to resolve an unresolved dual-residence situation. This is why a British person should not use the phrase “I am resident in France” without stating whether it means an immigration status, a French domestic tax status, or treaty residence.
The year of arrival needs a calendar. France generally assesses income on the calendar year, while the UK tax year runs from 6 April to 5 April. Record the date the French home became available, the date ordinary life moved, the date work or pension arrangements changed, the days spent in each country, and the date any UK home was let or retained. Keep evidence for both sides. HM Revenue and Customs’ guidance on tax when receiving a pension abroad confirms that moving abroad does not by itself make UK pension income disappear from the UK compliance file.
The treaty residence question can also affect savings, dividends, rental income and capital gains, even if the article’s central issue is a pension. A British bank account remains a foreign account once the holder is French tax resident. French residents may have to disclose foreign accounts and certain insurance or investment contracts. The official impots.gouv.fr page on foreign accounts explains that the obligation is connected with French tax domicile under Article 4 B, not with the person’s nationality.
The safe working method is to prepare a residence table rather than rely on memory. List each home, its availability, each family member’s location, each income source, the principal bank and investment relationships, and the travel dates. If the UK and France both appear to treat the person as resident, apply the treaty analysis before filing inconsistent declarations. A certificate from one tax authority may help, but it does not replace a factual review of the person’s home and life.
II. UK pension in France: how are tax, healthcare and first-year paperwork handled?
A. How is a UK State Pension or private pension taxed in France?
Start by classifying the payment. “UK pension” is not one legal category. It may mean the UK State Pension, a workplace pension, a personal pension, an annuity, a lump-sum withdrawal, a survivor’s pension, an incapacity or injury payment, or a pension paid by a public employer. The payer, the source, the employment history and the legal nature of the payment can change the treaty result.
French domestic law treats pensions as part of taxable income unless a specific exemption applies. Article 79 of the General Tax Code states: « Les traitements, indemnités, émoluments, salaires, pensions et rentes viagères concourent à la formation du revenu global servant de base à l’impôt sur le revenu ». The official Article 79 text also includes retirement benefits paid as capital. That does not mean France automatically taxes every UK pension: the treaty must then be applied to the classified payment.
For an ordinary pension paid in consideration of past private employment, Article 18 of the France–UK Convention is the central rule. The English treaty text published by the UK government states: “Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid in consideration of past employment to a resident of a Contracting State shall be taxable only in that State.” The relevant GOV.UK treaty publication and the corresponding Légifrance publication should be read together. For a treaty-resident of France, an ordinary UK private pension will commonly be allocated to France, subject to the nature of the payment and the other treaty provisions.
Government service pensions require a separate check. Article 19 generally addresses pay and pensions paid by a contracting state or public authority for services rendered to that state. The nationality exception and the type of public body matter. A former civil servant should therefore identify the pension scheme and obtain the payer’s written classification before assuming that Article 18 applies. A UK State Pension is not automatically the same thing as a UK civil-service pension.
The treaty also contains special rules for certain exempt pensions. Article 81 of the General Tax Code lists French domestic exemptions, including defined military-invalidity pensions and the combatant’s retirement pension in the circumstances stated by the text. The verified Article 81 wording on Légifrance should not be used as a blanket exemption for a standard UK State Pension. If a payment is an injury, disability or armed-forces benefit, preserve the award notice and the legal basis before deciding how it should appear on the return.
The UK tax side does not vanish because Article 18 points to France. The UK payer may continue to apply withholding until HMRC receives a residence or treaty-relief claim. The person should tell HMRC and the pension provider about the move, request a statement showing gross payments and tax withheld, and keep the UK tax-year records. If tax has been withheld in the UK when the treaty allocates the ordinary pension to France, the correction may involve a claim to HMRC rather than a refusal to declare the income in France.
The French filing route depends on the treaty mechanism. The French tax authority’s page on foreign-source income explains that the taxpayer should first consult the convention, then use declaration form 2047 where foreign income must be reported, and transfer the amounts to the appropriate boxes on the main return. The impots.gouv.fr pensions page distinguishes foreign pensions that open a right to a tax credit from pensions that are declared under other lines. The correct line is a consequence of the treaty classification, not a choice made because it produces the lowest immediate tax.
Do not confuse income tax with French social contributions. The treaty can allocate income-taxing rights, while CSG, CRDS and CASA depend on French social-security rules, the person’s tax income and the applicable health-insurance affiliation. CSG means contribution sociale généralisée, a general social contribution; CRDS means contribution pour le remboursement de la dette sociale, a contribution towards repayment of the social-security debt; CASA is the additional contribution for autonomy. Their application to a UK pension requires a separate review.
Article L. 136-8 of the Social Security Code currently states that « sont assujetties à la contribution au taux de 8,3 % les pensions de retraite, et les pensions d’invalidité », but the same provision contains reduced rates and thresholds. The current L. 136-8 text must be read with the pensioner’s reference taxable income, household quotient, exemption status and health affiliation. It is unsafe to multiply a gross pension by 8.3% without checking whether a reduced rate, exemption or different affiliation applies.
The official BOFiP guidance on foreign-source pensions also describes the general link between French tax residence, affiliation to a compulsory French health-insurance regime and social contributions. A UK pensioner covered by an S1 should not assume that the existence of the S1 alone decides the CSG question; the pension, residence, income and health-law facts must be aligned.
One published decision illustrates why the pension record matters. In Second Civil Chamber, 7 November 2019, no. 18-18.344, the Court of cassation dealt with a British national who had worked in the United Kingdom, France and Monaco. The verified decision explains that he could claim « la totalisation des périodes d’assurance acquises au Royaume-Uni et en France » in the circumstances of that case. This was a social-security coordination dispute involving the legal framework then applicable; it is not a universal promise that every person moving after Brexit can combine periods under old EU rules. It does, however, show why a complete career statement and the dates of UK and French insurance periods should be obtained before a pension calculation is challenged.
At the end of the first year, the pension file should allow a third party to answer five questions: what was paid, by whom, under which scheme, in which tax year, and where the treaty says it is taxable. If any answer is missing, the file is not ready for a cross-border declaration.
B. How do you secure healthcare, treaty relief and the first French tax return?
Healthcare should be organised before the move, not after the first illness. An S1 is a form used to register entitlement to healthcare funded by another state. A British resident in France who receives a UK State Pension or another exportable benefit may be entitled to an S1. The current GOV.UK healthcare guidance for UK nationals in France says that, once obtained, the S1 must be registered with the local CPAM, the Caisse primaire d’assurance maladie, which is the local French health-insurance office. Registration gives the holder and eligible dependants access on the relevant French basis; it is not the same as a private insurance policy.
If there is no S1, the person needs to identify the alternative route. It may be French employment or self-employment, another international arrangement, private cover required for a visa, or the French residence-based system once the statutory conditions are met. Article L. 160-1 of the Social Security Code provides that a person working in France or, without professional activity, residing there in a stable and regular manner, benefits from healthcare under the Social Security Code. The official Article L. 160-1 text uses the words « résidant en France de manière stable et régulière ». The provision is important, but it does not remove the need to meet the immigration, registration and contribution rules that apply to the individual.
The S1 does not answer the tax-residence question. Nor does the French tax number prove that France is treaty-resident state. Keep the healthcare file separate: S1, registration confirmation, CPAM correspondence, private policy, medical cover dates, dependants and any change of UK benefit. Tell the NHS Overseas Healthcare Team if the entitlement changes or the person returns permanently to the UK.
Treaty relief also needs a paper trail. Article 30 of the France–UK Convention requires a person seeking treaty benefits to provide a declaration and an attestation from the tax authority of the other state confirming residence for the relevant period. The verified text refers to « une attestation de l’administration fiscale de l’autre Etat contractant confirmant que le requérant est ou était … un résident de cet autre Etat ». In practice, a claim should identify the pension, the relevant tax year, the treaty article relied upon, the country of treaty residence, the gross amount and any tax already withheld. The official treaty text is the source to use when the payer or tax authority asks which article applies.
The first French tax return normally requires more preparation than a domestic return. A new resident should create a schedule with:
- each UK State Pension payment and the gross annual amount;
- every workplace, personal or overseas pension, including lump sums and withdrawals;
- the payer’s name, scheme type, payment currency and tax withheld;
- the date French tax residence began and the days in France and the UK;
- UK interest, dividends, rental income and capital transactions;
- French and foreign bank accounts, insurance contracts and investments that may require a separate disclosure;
- the S1 or other health-insurance status; and
- the treaty article and filing box used for each pension.
Foreign amounts should be converted consistently using the method accepted for the return, with the calculation retained. Keep annual statements, bank entries, HMRC correspondence, DWP letters, pension-provider certificates, exchange-rate evidence and copies of every form submitted. If a French tax office asks why a UK pension was not taxed in France, the answer should be a documented treaty analysis, not a recollection of a telephone conversation.
The first return may also be the point at which a filing error becomes visible. A French tax notice can show an incorrect pre-filled amount; a UK pension may arrive without a French withholding line; a tax authority may use the wrong pension category; or a person may have filed as a non-resident even though the family home was already in France. Correct the return through the appropriate channel and preserve the original submission, the correction and the supporting evidence.
A person who remains connected with both countries should also review the estate consequences of the move. A UK will, pension nomination and French succession planning do different jobs. The pension provider’s nomination form may determine who receives a death benefit, while the will governs assets that fall into the estate and French or international succession rules may affect the result. A spouse, civil partner, children and dependants should be identified before the move, not only after a death. The review should include the governing law of the will, the location of assets, beneficiary designations, life insurance, possible French inheritance tax and the effect of a future change of residence.
For a family living in Paris or Île-de-France, the same legal sequence applies, but the practical administration may involve a local prefecture, the relevant CPAM and the competent tax office. Keep the appointment confirmations and receipts. A failed online submission, an incomplete prefecture appointment or a delayed S1 registration should be documented immediately, because the evidence may matter when a residence card, healthcare reimbursement or tax position is later questioned.
A useful first-year timetable is therefore:
- Before departure, choose the immigration route, obtain the visa if required, notify HMRC and pension providers, obtain health cover or request the S1, and collect civil-status and pension documents.
- On arrival, validate the visa or apply for the residence document, register healthcare, obtain the French tax identifiers and record the date the French home became the centre of daily life.
- Before the first filing, classify every payment, check the France–UK treaty, prepare forms 2042 and 2047 where relevant, review foreign-account disclosures and compare the French and UK records.
- After filing, check the tax assessment, UK withholding, social contributions and healthcare registration. Correct discrepancies in writing and keep proof of every request.
The objective is not to create two contradictory tax stories. It is to make the immigration, tax, pension and healthcare records describe the same reality. Where they do not, obtain advice before a return, treaty claim or residence renewal is submitted.
Conclusion
For a British person moving to France after Brexit, the critical sequence is residence route first, factual tax residence second, pension classification third, and healthcare and treaty paperwork immediately afterwards. The Withdrawal Agreement may protect an established pre-2021 resident, but a new mover generally needs the ordinary long-stay route. Article 4 B of the French tax code and Article 4 of the France–UK treaty then determine residence by looking at the person’s real home and life, not only at the passport or the number of days remembered. Article 18 commonly directs an ordinary private pension to the country of treaty residence, while public-service pensions and special benefits require separate treatment. Every pension should still be declared, and social contributions and healthcare must be analysed independently.
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