Can you move to France after Brexit and keep your job with a British employer? Sometimes, but the answer is not decided by the country that pays your salary, the bank account receiving it, or a casual reference to the 183-day rule. The decisive facts are where you physically perform the work, whether France is your normal place of work or only a temporary assignment, which country’s social-security legislation applies, where you are tax resident, and whether your French immigration status permits employment.

A British employee working from a French home can therefore face four separate questions at once: a residence and work authorisation question, a French payroll and social-security question, a France–UK income-tax question, and an employment-law question. Brexit did not make every cross-border arrangement impossible, but it removed the assumption that an existing UK contract automatically follows the worker into France. The safest approach is to classify the arrangement before the first French working day, preserve the documents that prove that classification, and obtain a written position from the employer on payroll, social security and tax. This guide explains the main routes, the limits of an A1 certificate, the evidence to keep, and the steps to take when the employer continues paying UK payroll while you work in France.

I. Can I work remotely from France for a UK employer after Brexit?

A. What changes if France is your normal place of work?

The first distinction is between a British employee who remains based in the United Kingdom and is sent to France for a defined mission, and a person who has moved their home and ordinary working life to France. Calling the second arrangement “remote work” does not remove the legal consequences of working on French territory. The physical place where the work is performed is a primary fact for labour law, social security and often taxation.

French law defines telework in functional terms. Article L. 1222-9 of the Labour Code says, in the original wording, Le télétravail désigne toute forme d’organisation du travail. The point is that work which could have been done at the employer’s premises is carried out elsewhere using information and communication technology. A UK employment contract may remain the contractual starting point, but it does not make the French home legally invisible. If the employee lives and works from France on an open-ended or settled basis, the employer must analyse French rules rather than rely solely on UK payroll.

Social security starts with the same territorial reality. Article L. 111-2-2 of the Social Security Code provides that, subject to international agreements, people who work in France for one or more employers are affiliated to a compulsory social-security scheme. Its operative wording is sont affiliées à un régime obligatoire de sécurité sociale. The fact that the employer has no French office does not, by itself, create an exemption. Nor does payment in sterling, a UK payslip, or continued National Insurance deductions prove that UK legislation applies.

The official UK guidance states the same practical starting point in English: If you work abroad, you will usually pay social security contributions (called National Insurance contributions in the UK) in the country where you’re working. The word “usually” matters. An international agreement can allocate social security to the United Kingdom for a temporary posting or another defined multi-state situation. It does not turn every permanent move to France into a posting.

For a permanent French base, the likely compliance route is for the British employer to arrange French registration and payroll obligations, either directly through the available foreign-employer procedures or with an appropriate payroll provider. Article L. 243-1-2 of the Social Security Code expressly addresses l’employeur dont l’entreprise ne comporte pas d’établissement en France and provides for declarations and payment of the required social contributions through a designated collection body. The official Urssaf guidance for foreign firms should be read with the individual facts: Urssaf is the French organisation that collects many social contributions, and the route differs according to whether the employer has a French establishment, whether the employee is already covered elsewhere, and whether the work is temporary.

In a straightforward permanent remote-work arrangement, the employer should not describe the worker as an independent contractor merely to avoid French payroll. A genuine employee normally has continuing instructions, fixed remuneration, integration into the employer’s organisation and a relationship of subordination. Re-labelling that relationship can create additional risk. Article L. 8221-5 of the Labour Code describes concealed salaried employment by reference to failures involving the prior hiring declaration, payslips and salary or social-contribution declarations; the provision begins Est réputé travail dissimulé par dissimulation d’emploi salarié. A British employee should not sign a consultancy agreement without checking whether the actual working relationship has changed in substance.

The hiring formalities are not theoretical. Article L. 1221-10 of the Labour Code states that L’embauche d’un salarié ne peut intervenir qu’après déclaration nominative to the relevant social-protection bodies. For an employee already hired in the UK who relocates to France, the exact filing route may not be the same as a new French recruitment, but the employer still needs a documented answer on the French declarations, payslips, contributions and applicable employment rules.

French employment law also matters where the contract is governed partly by UK terms. Working time, rest, health and safety, discrimination, annual leave, dismissal protection and the organisation of telework cannot be treated as optional because the employer’s headquarters are in Manchester, London, Edinburgh or Belfast. Article L. 1222-9 gives a teleworker the same rights as an employee working on the employer’s premises and requires the arrangement to be organised through a collective agreement, an employer charter or a formal agreement by another written method where applicable. The Supreme Court has applied that equality principle in its decision of 24 April 2024, no. 22-18.031, which refers to the rule that le télétravailleur a les mêmes droits que le salarié qui exécute son travail dans les locaux de l’entreprise. The decision concerned an employee benefit rather than an international move, but it is a useful reminder that telework is not a lower category of employment.

Immigration status is a separate gate. A British citizen who was already legally resident in France before 1 January 2021 may have rights under the Withdrawal Agreement and hold a Withdrawal Agreement residence permit, known in French as a carte or titre de séjour “accord de retrait”. A person arriving after that date generally needs the visa or residence permit corresponding to the planned activity. The current GOV.UK guidance on living in France warns that a British national may need a work permit or work visa, including where the employer is based in the UK. The French visa service’s Brexit guidance also distinguishes the pre-2021 protected population from later arrivals.

This means that a “visitor” status should not be assumed to authorise a full-time job performed from France. A long-stay visitor visa, a family-based permit, a permit issued for a different activity, and a permit authorising salaried employment do not necessarily have the same scope. If your proposed arrangement is a permanent job performed from a French home, check the residence and work authorisation before moving, not after the first payslip. A residence permit renewal problem can also affect the right to continue working; the practical response is addressed in our guide on what to do when a Brexit residence-permit renewal is refused.

B. When can a temporary posting keep you in the UK system?

The second route is a genuine temporary posting, called détachement in French. It is not simply a label placed on a permanent home move. The employee normally works in the United Kingdom, remains attached to the UK employer, is sent to France for a defined period, and returns or remains expected to return to the normal UK employment arrangement. The employer must be able to show the assignment, the continuing employment relationship, the planned duration and the absence of an artificial structure designed only to avoid French obligations.

Article L. 1262-1 of the Labour Code recognises the possibility for an employer established outside France to temporarily post an employee in France while the employment contract and relationship continue. The relevant provision says that Un employeur établi hors de France peut détacher temporairement des salariés sur le territoire national subject to the statutory conditions. This is a labour-law concept. Social security requires a separate analysis and a certificate proving which legislation applies.

For a UK employer sending an employee to France after Brexit, the Trade and Cooperation Agreement preserves a form of temporary social-security coordination. In practical terms, an A1 certificate, or UK certificate of coverage, can confirm that UK social security remains applicable during a qualifying posting. The official GOV.UK guidance for employees working abroad explains that an employee temporarily working in an EU country may continue UK National Insurance where the conditions are met. It also states that The certificate of coverage is evidence that no social security contributions are due in the other country. That document is evidence of an allocation of legislation; it is not a general permit to ignore French rules.

The French–UK operational guidance commonly used by employers limits the post-Brexit posting route to 24 months for situations beginning from 2021. The Urssaf international-mobility service explains that the certificate route depends on the type of mobility and on the countries and conditions concerned. For a UK-to-France assignment, the employer should apply through the competent UK institution and obtain the certificate covering the actual dates. A certificate requested after an audit, after a health-care dispute, or after contributions have accumulated is much weaker evidence than a certificate obtained before the assignment begins.

A temporary posting normally requires more than a short email saying “work from France”. Keep the assignment letter, the UK contract, the planned end date, the place of work, the reporting line, proof that the UK employment continues, travel records, payslips, the A1 or certificate of coverage, and correspondence with the employer’s payroll team. If the employee never had a normal UK working base, intends to remain in France indefinitely, or has moved their household and economic life permanently, those facts may point away from a posting even if the employer calls it one.

The 24-month period is a ceiling, not an entitlement to remain in the UK system for any chosen 24 months. The posting must satisfy the substantive conditions. The employee should ask whether they are replacing another worker, whether the assignment is a service performed in France or merely personal remote work, whether the employment relationship remains with the UK employer, and whether the assignment is genuinely temporary. The employer should identify the institution issuing the certificate, the exact legislation covered, and the process if the worker’s time in France changes.

Hybrid working is more difficult. Someone who spends three days each week in France and two days in the UK may not fit the same analysis as someone who spends six months in France on a single posting. The competent institution may assess residence, the proportion of activity in each country, the employer’s location and the actual working pattern. A travel diary and calendar are essential because the tax treaty and the social-security rules answer different questions. A1 coverage does not decide income tax, and tax residence does not decide social security.

Work performed in France can also affect the employee’s legal protections even when the company has no French office. The French Supreme Court’s decision of 21 October 2020, no. 19-15.453 concerned hours worked in a telework arrangement and restated that a court cannot reject an overtime claim by placing the entire evidential burden on the employee. The decision records the principle in the wording le juge ne peut, pour rejeter une demande en paiement d’heures supplémentaires, faire peser sur le seul salarié la charge de la preuve. A cross-border worker should therefore keep working-time records, contact schedules, instructions, time sheets and evidence of the hours actually worked.

There is a further distinction between a UK employee temporarily sent to France to serve a UK business and a worker who is recruited specifically to live and work in France. The first may be a posting. The second will normally require a French-compliant employment and social-security solution. If the facts are mixed, do not decide by counting days alone: document the ordinary place of work, the contractual expectation of return, the employer’s instructions, the immigration status, the certificate and the payroll treatment together.

II. What must you arrange for tax, payroll and residence?

A. How are your salary and French tax returns handled?

Tax residence is not the same as social-security affiliation. A person may be tax resident in France while an A1 certificate temporarily keeps them in the UK social-security system. Conversely, a person may have a UK employer and remain taxable in France because the work is physically performed from France. The analysis begins under French domestic law and is then tested against the France–UK tax treaty.

Article 4 B of the General Tax Code identifies French tax domicile by reference to the home or principal stay, professional activity and centre of economic interests. It includes people qui exercent en France une activité professionnelle, subject to the treaty rules. That does not mean every British employee who opens a laptop in France becomes French tax resident immediately, but it does mean that a permanent French home and ordinary professional activity are powerful facts. Counting fewer than 183 days is not a substitute for analysing the whole household and economic position.

The France–UK Convention of 19 June 2008 contains its own residence tie-breaker. Article 4 first looks at the person’s permanent home and then at the closer personal and economic links, described in the official text as the foyer d’habitation permanent and the centre of vital interests. If that cannot decide the matter, the treaty moves to habitual abode and nationality. The treaty does not allow a person to choose the country with the lower tax merely by keeping a UK address or a British bank account.

Employment income is dealt with by Article 15 of the Convention. The official text covers les salaires, traitements et autres rémunérations similaires and generally assigns the taxing right to the country of residence unless the employment is exercised in the other country. If the work is exercised in France, France can have the taxing right. The well-known 183-day exception is conditional: the employee must remain within the day limit, the employer must not be resident in the other state, and the remuneration must not be borne by a permanent establishment there. All conditions must be satisfied. The day count alone is not enough.

A British resident visiting France for a defined assignment may therefore fall within the treaty exception if the employment is exercised in France for no more than 183 days in the relevant period and the other conditions are met. A French resident who works regularly from France for a UK employer is in a different position. Even when UK PAYE continues to operate, the worker may need to declare the salary in France and claim the treaty mechanism that prevents double taxation. The employer’s payroll decision is not a tax-residence certificate.

French residents must report foreign income under the French filing rules. Article 170 of the General Tax Code states that toute personne imposable audit impôt est tenue de souscrire an income declaration. The official impots.gouv.fr explanation of foreign income identifies the main declaration, the 2047 annex for foreign income and the relevant 2042-C forms. The exact box depends on the type of income and the treaty result; do not copy a form number from another worker without checking the year and the nature of the salary.

The French tax administration’s France–UK information sheet also identifies salary from private employment exercised in France as a category that may have to be declared in France, while describing the treaty exceptions. It is available through the official France–UK tax information page. Keep the gross salary figures, payslips, UK tax withheld, dates worked in each country, tax-residence evidence and any certificate supplied by the employer. If the French return requires the gross amount before UK deductions, using the net amount can produce a mismatch and a request for clarification.

Double taxation relief is a treaty question, not a promise that no tax will be due anywhere. Article 24 of the Convention provides the mechanism by which les doubles impositions sont éliminées. Depending on the allocation of taxing rights, the relief may be an exemption with progression or a tax credit. The return may still require the income to be disclosed even if the final French tax is reduced. The UK filing position must be checked separately under HMRC rules, especially where the employee performed some duties in the United Kingdom during the same tax year.

The treaty also contains a mutual-agreement procedure. If the worker believes that France and the United Kingdom are taxing the same income contrary to the Convention, Article 26 allows the case to be submitted to the competent authority. The text refers to the ability to soumettre son cas à l’autorité compétente and imposes time limits connected to the first notification or the relevant tax year. That is a later remedy, not a substitute for filing correctly and preserving evidence from the beginning.

Do not assume that continued UK National Insurance solves the pension question either. The GOV.UK National Insurance guidance explains that voluntary UK contributions may protect State Pension entitlement but do not provide health insurance in the country where the person lives. If French affiliation is required, the worker should obtain proof of registration and understand how contributions are credited. The cross-border pension article on UK pensions in France after Brexit covers the separate treatment of pension income; the present question concerns remuneration from active work.

B. Which residence, employment and evidence steps protect you?

Before moving, prepare a written file that answers the following questions in plain terms:

• Where will the worker sleep, keep their main home and perform the majority of duties?
• Is the arrangement permanent, open-ended, or a temporary assignment with a defined return to the United Kingdom?
• Which residence permit or visa authorises the intended work in France?
• Which institution will collect social contributions, and will the employer issue a French payslip?
• Is an A1 or certificate of coverage available, for which dates, and for which activity?
• Which country will receive the salary declaration, and how will any foreign tax credit or exemption be claimed?
• How will working time, annual leave, sickness, accident reporting, equipment and home-office costs be handled?

The first document should be a contract amendment or mobility letter, not an informal chat message. It should identify the French address or region of work, the start date, the expected duration, the reporting line, the working days in each country, the applicable payroll route, insurance arrangements, equipment, confidentiality and the process for returning to the UK. It should say whether the employer treats the move as a posting or as a permanent change of work location. If the document is silent while the worker is already living in France, ask for a written clarification before the position becomes difficult to unwind.

The second document is proof of immigration permission. A British citizen who arrived before 2021 should keep the residence permit, renewal receipts, prefecture correspondence and evidence of continuous lawful residence. A person who arrived later should keep the visa, validation certificate, residence permit, work authorisation and any employer documents used in the application. The France-Visas salaried-employment guidance distinguishes employee and temporary-worker categories and explains that the visa or permit must correspond to the activity. A job that is permitted in the United Kingdom is not automatically permitted under a French visitor status.

The third document is the social-security allocation. If the arrangement is a genuine temporary posting, request the A1 or certificate of coverage before the French assignment. Keep the application, the decision, the covered dates and the employer’s instructions. If the arrangement is permanent, ask the employer to confirm the French registration route and the body receiving contributions. The Urssaf service for a foreign company employing a person in France describes a simplified route for some employers without a French establishment; it does not mean every case can be handled through the same form.

The fourth document is the workday record. Record where the work was physically performed, not merely where the employer’s server or payroll system was located. Keep travel tickets, calendar entries, meeting records, home-office days, office access records and any UK business-trip schedule. This record is useful for the France–UK tax treaty, for a social-security review, for an immigration application and for an employment dispute. If the employer asks the employee to work in France but later asserts that all duties were performed in the UK, the contemporaneous record becomes important evidence.

The fifth document is the payroll and tax pack: payslips, annual summaries, UK tax certificates, French tax notices, the 2047 annex where relevant, tax-residence certificates, records of tax withheld and all correspondence about double-tax relief. The official UK guidance for employers explains that PAYE and National Insurance treatment may change when an employee works abroad and that separate payroll arrangements may be needed. A French tax declaration may still be required even if UK PAYE was deducted, and UK payroll may still need adjustment even if the worker is French tax resident.

Three common scenarios illustrate the difference.

Permanent move to France. The worker has relocated their household, works from France every week and has no defined return date. The employer should not rely on a UK contract and UK payslip alone. Immigration permission, French social-security affiliation, payroll declarations, French employment protections and tax reporting must be addressed. If a British citizen is using a visitor status, obtain advice before working because the residence document may not authorise the activity. The 183-day rule does not convert a permanent French work base into a UK-only tax arrangement.

Temporary assignment from a UK base. The worker remains normally based in the United Kingdom, is sent to France for a defined project, continues under the UK employer’s direction and has a planned end date. An A1 or certificate of coverage may preserve UK social security for a qualifying period, generally limited to 24 months after Brexit. The worker still needs to check French work authorisation and employment formalities for the assignment. The certificate should be obtained and retained before the start date.

Regular work in both countries. The worker spends part of the week in a French home and part in a UK office, or travels regularly to clients. The position depends on residence, the proportion of activity, the employer’s location, the treaty facts and the social-security coordination rules. A monthly average is not always enough. Prepare a calendar showing each working day, obtain a written assessment from the employer and ask the competent social-security institution to confirm the applicable legislation. Tax and social-security results may diverge.

If the employer refuses to regularise the arrangement, begin by asking for the refusal in writing. Identify whether the problem is immigration, French payroll, social security, tax withholding, insurance or an internal policy. A worker who is told “the UK contract is enough” should ask which rule supports that conclusion and whether an A1 or certificate exists. A worker who is suddenly told to become a contractor should compare the new contract with the actual instructions, working hours, reporting line and financial dependence. Do not sign a document that changes status without reviewing the consequences.

When a French contribution dispute has already begun, preserve notices, payment demands, payslips and the dates of work. When a tax dispute has begun, preserve the treaty analysis, residence evidence and both countries’ notices. Article 26’s mutual-agreement route may help with a treaty conflict, but ordinary French and UK appeal deadlines continue to run. A request for dialogue with an employer or authority is not automatically a suspension of a formal deadline.

Paris and the Île-de-France region do not create a separate Brexit tax treaty or a special remote-work exemption. The competent prefecture, tax office, Urssaf body and employment tribunal depend on the address and the legal issue. A worker living in Paris should therefore keep the address evidence and identify the local administrative channel rather than assume that a London payroll department can complete every French step. The same principles apply elsewhere in France, with practical differences in appointments and processing times.

Finally, keep the categories separate in every email. Say “immigration permission” when you mean the right to live and work in France; “social-security legislation” when you mean the country collecting contributions; “tax residence” when you mean the country claiming residence under domestic law and the treaty; and “employment law” when you mean the rights and obligations attached to the contract. An A1 is not a visa. A tax-residence certificate is not a work permit. A UK payslip is not proof that French contributions are unnecessary. Clear wording prevents the most common cross-border errors.

For a broader first-year checklist covering residence, healthcare, tax and daily administration, see our guide to moving to France from the UK after Brexit. If the health-registration consequences of a French move are the immediate problem, our guide to S1 registration and a CPAM refusal addresses that separate process.

Need a quick opinion on your case

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We can review your French residence status, UK employment contract, work pattern, A1 or certificate of coverage, payroll and tax documents before the situation becomes a dispute.

Call +33 6 46 60 58 22 (Maître Reda Kohen), or use the contact page. Advice can be arranged for clients living in Paris and Île-de-France as well as elsewhere in France.

Conclusion

A UK employer can sometimes keep a British employee working from France after Brexit, but the lawful route depends on the facts. A genuine temporary posting may support an A1 or certificate of coverage for a limited period. A permanent French work base usually requires a French immigration, employment, social-security, payroll and tax analysis. The 183-day rule is conditional, a UK payslip does not settle French obligations, and an A1 certificate does not authorise residence or employment. Classify the arrangement first, obtain the correct permission and certificate, record each working day, and keep the employer’s position in writing. That sequence gives the worker a defensible file and gives both sides a chance to correct the structure before a tax, payroll or residence refusal makes the issue urgent.