You have retired to France and the monthly payments have started to land in your French bank account: a final-salary annuity from a former UK employer, a regular drawdown from a self-invested personal pension (SIPP), or both. The question that follows is always the same, and it is asked every autumn in Dordogne, Brittany and Paris alike: does the United Kingdom keep a slice, does France tax the whole amount again, and what paperwork proves that you should not pay twice? Since Brexit changed nothing in the tax treaty but everything in residence law, the answer sits at the crossing of three sets of rules: the 2008 France-United Kingdom double tax convention, which gives France the main right to tax your private pension; the French domestic rules on declaring foreign pensions and on the 10 per cent allowance; and the social-charge rules, where holding a British S1 healthcare certificate can remove the bill entirely. This article walks through the full chain in order. It explains which country taxes a defined-benefit annuity or a SIPP drawdown and where government-service pensions break the pattern, how to declare the pension on the French foreign-income return and how the allowance softens the rate, when the 8.3 per cent social charge applies and when the S1 exempts you, how arrears and leftover British withholding are fixed, and how to challenge double taxation step by step. Every determining proposition is anchored to the treaty text, the statute or a numbered court decision quoted word for word.

I. How is my UK private pension taxed when I live in France after Brexit?

A. Which country taxes your final-salary annuity or SIPP drawdown: Article 18 and the Article 19 exception for government service

The starting point is the residence principle in the treaty signed in London on 19 June 2008 and in force between the two countries. Article 18 of the France-United Kingdom convention on GOV.UK gives the state of residence the sole right to tax pensions and other similar remuneration paid for past employment, subject only to the government-service exception in paragraph 2 of Article 19. If you are resident in France for treaty purposes, your private-sector pensions, meaning a final-salary or career-average annuity from a British employer scheme, a money-purchase annuity bought with a SIPP, and regular SIPP flexi-access drawdown paid as pension income, are taxable only in France. The United Kingdom must therefore stand back, and any British tax deducted at source on those payments is an amount to reclaim rather than a shared charge. The French tax administration says the same thing from its own side: the impots.gouv.fr guidance on foreign-source income directs French residents to the treaty signed with the country of origin to determine whether the income is taxable in France, whether it must be declared there, and how any double taxation is eliminated where both countries have taxed it.

Three boundaries matter before you rely on that sentence. First, it covers pensions paid for past employment. A periodic annuity and a regular drawdown drawn as pension income sit squarely inside it, while a one-off lump sum raises separate questions of characterisation that are examined in our companion guide to UK pension lump sums and QROPS transfers for British residents in France. Second, the opening reservation for paragraph 2 of Article 19 carves out government-service pensions entirely. Article 19 of the same convention on GOV.UK reserves pensions paid by a state, its local authorities or, for France, a statutory body for services rendered to that body to the paying state alone, with a single flip: the pension moves to the other state only where the individual is resident and a national of that other state without also being a national of the paying state. A British civil-service, armed-forces, police, fire-service, teacher or NHS pension paid out of public funds therefore stays taxable in the United Kingdom as a rule, and it flips to France only where you are French resident, hold French nationality and do not also hold British nationality. Check the identity of the payer before anything else, because applying Article 18 to a civil-service pension, or Article 19 to a private company scheme, is the most common and most expensive classification error in British files.

Third, the treaty preserves a handful of historic exemptions that override both articles. Paragraph 4 of Article 19 keeps French tax off certain British war, injury and service pensions that are exempt in the United Kingdom, and keeps British tax off certain French pensions listed in paragraph 4 of Article 81 of the French tax code for as long as they are exempt in France. If your pension compensates a war injury or service-attributable disablement, verify the exemption before declaring anything, because an exempt pension should never enter the computation at all. Where none of these exceptions applies and you hold an ordinary private pension as a French resident, the treaty position is clean: France taxes, the United Kingdom relieves. The practical consequence is that you should ask HM Revenue and Customs for treaty relief at source so that future payments arrive without British withholding, and separately reclaim any British tax already withheld, while declaring the full pension in France as explained below. The two procedures run in parallel and neither replaces the other. Readers who need only the withholding-recovery mechanics will find them step by step in our guide to declaring a UK private pension and recovering British tax withheld, while readers whose scheme refuses any gross payment at all should start with our guide to a UK SIPP provider refusing gross payment to a French resident; the present article covers the complete periodic-pension chain, from treaty classification and the 10 per cent allowance to social charges, arrears and challenge.

France then eliminates any residual double taxation on its own side through a credit mechanism rather than an exemption. Article 24 of the convention on GOV.UK provides that, for the income it covers, a French resident who remains subject to United Kingdom tax on that income receives a French tax credit equal to the French tax attributable to the same income. In plain terms, where a slice of British tax has lawfully survived, because relief at source was refused or arrived late, France credits an amount equal to the French tax on that same income, so the combined burden cannot exceed the higher of the two charges. Keep every British payslip, P60 and withholding certificate, because the credit is computed income by income and the French inspector will ask for the British paperwork before granting it.

B. How France taxes your UK pension in practice: the foreign-income return, the 10 per cent allowance and the progressive scale

French domestic law taxes worldwide income once you are domiciled in France for tax purposes, and it does so through a yearly paper chain that starts with a declaration duty. Article 170 of the French general tax code on Légifrance provides: “toute personne imposable audit impôt est tenue de souscrire et de faire parvenir à l’administration une déclaration détaillée de ses revenus”, meaning every person liable to income tax must file a detailed return of income with the administration. For a British resident this means three coordinated filings each spring: the main return, form 2042, the foreign-income return, form 2047, on which the British pension is entered with its country of origin, and, where a treaty credit is claimed for British tax withheld, the corresponding credit section carried back onto the main return. Declare the gross British pension converted into euros at the rate applicable for the year, attach the British certificates, and tick the pension boxes as pension income rather than salary, because salary treatment would cost you the allowance described next and could trigger the wrong social-charge coding.

The allowance is the single most valuable domestic relief on pension income. Article 158 of the general tax code on Légifrance provides: “Les pensions et retraites font l’objet d’un abattement de 10 % qui ne peut excéder 4 439 €.” Pensions and retirement income therefore benefit from a 10 per cent deduction capped at 4,439 euros under the current figures, with a floor of 454 euros per pensioner and yearly indexation of both figures. The ceiling applies across all pensions of the household, so a couple receiving a British annuity each plus a French pension shares one household cap while each spouse keeps the minimum. Concretely, a British annuity of 30,000 euros a year enters the scale at 27,000 euros, and a combined 60,000 euros of household pensions enters at 55,561 euros under the current figures. Verify the cap for the year of assessment before filing, because the amount moves every year with the top of the first income-tax band and last year’s figure is the classic source of a 200-euro reassessment.

After the allowance, the net pension joins the rest of the household income and runs through the progressive household scale, the barème with its family-parts divisor, the quotient familial. Two consequences follow that British newcomers often miss. First, the British pension can push French-source income into a higher band, and French-source income can push the British pension up the scale, because France computes the rate on worldwide income even where the treaty reserves parts of it. Second, the pension counts in full for the income thresholds that open or close other French reliefs, from the reduced social-charge rate to local benefits, so understating it to save income tax can backfire across the file. By contrast, a British pension paid to someone who is not domiciled in France for tax purposes never enters this machinery at all: Article 182 A of the general tax code on Légifrance provides that “les traitements, salaires, pensions et rentes viagères, de source française, servis à des personnes qui ne sont pas fiscalement domiciliées en France donnent lieu à l’application d’une retenue à la source”, meaning French-source pensions paid to non-residents suffer a flat withholding instead. That sentence is your mirror test: if you genuinely live in France year-round, you belong in the declaration system with the allowance, not in the withholding system, and a French payer still applying the withholding to a French-resident Briton should be corrected with a residence certificate.

One further domestic point protects readers who built pension rights in both countries. In a decision concerning a British national who had worked in the United Kingdom, France and Monaco and drew a French old-age pension cut to a 32.50 per cent reduced rate, the Second Civil Chamber of the Court of Cassation approved adding together the insurance periods completed in the United Kingdom and in France under the European coordination regulations, separately from the France-Monaco bilateral total, and awarding the higher of the two resulting pensions. Court of Cassation, Second Civil Chamber, 7 November 2019, appeal No. 18-18.344 holds: “M. X… qui ne pouvait prétendre à davantage de droits qu’un ressortissant français, pouvait revendiquer la totalisation des périodes d’assurance acquises au Royaume-Uni et en France par application des règlements de coordination communautaires, d’une part, et la totalisation des périodes d’assurance validées en France et dans la Principauté de Monaco par application de la convention franco-monégasque, d’autre part, la pension la plus élevée des deux devant lui être attribuée ;” Since Brexit the coordination regulations continue to apply within the scope of the Withdrawal Agreement for persons covered by it, so a Briton who paid National Insurance before settling in France should still have those years counted toward opening French pension rights, and a refusal that ignores the British periods should be challenged with the decision in hand.

II. What about social charges, arrears and double tax on your UK pension?

A. CSG and CRDS on your UK pension: when the S1 exempts you, when France charges 8.3 per cent, and how to prove it

Income tax is only half the French bill. On top of it France levies social charges, the prélèvements sociaux, principally the generalised social contribution (CSG, contribution sociale généralisée) and the contribution to repay the social debt (CRDS, contribution au remboursement de la dette sociale). Whether your British pension bears them depends on one question: are you covered by a compulsory French health insurance scheme, or do you hold a British S1 that keeps you under the British system? Article L. 136-1 of the social security code on Légifrance provides: “Il est institué une contribution sociale sur les revenus d’activité et sur les revenus de remplacement à laquelle sont assujettis : 1° Les personnes physiques qui sont à la fois considérées comme domiciliées en France pour l’établissement de l’impôt sur le revenu et à la charge, à quelque titre que ce soit, d’un régime obligatoire français d’assurance maladie”, meaning the charge bites only on persons who are both domiciled in France for income tax and covered by a compulsory French health insurance scheme. A British pensioner registered at the local health insurance fund (CPAM, caisse primaire d’assurance maladie) on an S1 certificate, whose healthcare costs are billed back to the United Kingdom, is not covered by the French scheme as an insured person and therefore falls outside the charge, while a pensioner affiliated to the French universal scheme (PUMA, protection universelle maladie) without an S1 falls inside it. Registration is the visible proof: the British official guidance on healthcare in France including the S1 on GOV.UK requires S1 holders to register the form at the local CPAM office, after which the holder receives care on the same basis as a French resident but remains funded by the United Kingdom.

Where the charge does apply, the rate on pensions is fixed by statute and it is higher than many Britons expect. Article L. 136-8 of the social security code on Légifrance provides: “Sont assujetties à la contribution au taux de 8,3 % les pensions de retraite, et les pensions d’invalidité.” Retirement and invalidity pensions therefore bear CSG at 8.3 per cent at the full rate, plus the CRDS alongside it, once the affiliation condition is met. A reduced CSG rate of 3.8 per cent exists for pensioners whose tax income of two years earlier stays beneath statutory thresholds, indexed per household part, and a full exemption applies at the very bottom of the scale, so the exact band must be recomputed every year from the reference tax income (revenu fiscal de référence) shown on the tax notice of two years before. A British annuity that looks modest in pounds can cross a threshold once converted and added to a spouse’s income, which is why the reduced rate won one year is regularly lost the next without any change in the pension itself. Readers disputing a CSG or CRDS bill on a British pension will find the detailed recovery route in our companion guide to CSG and CRDS on UK pensions, S1 refunds and how to challenge, including the refund mechanics where charges were wrongly levied on an S1 holder.

The legal backbone of every S1 exemption claim is the single-legislation principle stated by the Court of Cassation in the lineage of the De Ruyter judgment of the Court of Justice of the European Union. In a September 2025 decision on overlapping French and foreign social-security levies, the Second Civil Chamber recalled the rule in these terms. Court of Cassation, Second Civil Chamber, 25 September 2025, appeal No. 22-24.634 holds: “la personne à laquelle les règlements s’appliquent n’est soumise qu’à la législation d’un seul État membre, en sorte que celle-ci, affiliée à un régime de sécurité sociale d’un État membre, ne doit pas contribuer au régime de sécurité sociale d’un autre État membre (CJUE, arrêt du 26 février 2015, De Ruyter, C-623-13, point 35).” The facts there concerned a person living in France and working in Switzerland, so the decision must be used for the principle it states rather than copied onto different facts, but the principle is exactly the one that protects an S1 holder: a person affiliated to the social-security legislation of one state must not pay into the scheme of another for the same period. In practice the file should contain, in this order, the S1 certificate and its CPAM registration receipt, the British proof of exportable benefit or State Pension that founded the S1, the French tax notices showing the charges, and a dated claim letter identifying each levy line by line. Readers drawing the British State Pension itself, rather than a private pension, should cross-check the declaration and uprating position in our guide to UK State Pension for British residents in France, because the State Pension opens the S1 door that then shelters the private pension from the charges.

B. Pension arrears, leftover British withholding and how to challenge double taxation step by step

British pensions frequently arrive with a backlog: a final-salary scheme pays two years of arrears after a delayed retirement calculation, a SIPP provider corrects an underpayment in one lump, or HM Revenue and Customs releases treaty relief late so a full year of British withholding lands in a single French assessment. French law offers a targeted answer for income that is exceptional by nature or late by accident, the quotient system. Article 163-0 A of the general tax code on Légifrance provides for exceptional income: “l’intéressé peut demander que l’impôt correspondant soit calculé en ajoutant le quart du revenu exceptionnel net à son revenu net global imposable et en multipliant par quatre la cotisation supplémentaire ainsi obtenue.” Where the arrears correspond by their normal due date to earlier years through no choice of the taxpayer, the same article offers the deferred-income variant: “l’intéressé peut demander que l’impôt correspondant à ce revenu différé net soit calculé en divisant son montant par un coefficient égal au nombre d’années civiles correspondant aux échéances normales de versement augmenté de un, en ajoutant à son revenu net global imposable le quotient ainsi déterminé, puis en multipliant par ce même coefficient la cotisation supplémentaire ainsi obtenue.” The request is made on the return itself, it must identify the arrears year by year with the scheme’s statements, and it regularly saves a full band of tax where three years of pension fall into one assessment. Do not confuse this quotient with income-averaging: it does not spread the income, it neutralises the progressivity spike, and it must be claimed expressly, because the computer will otherwise tax the whole backlog at the top marginal slice.

Leftover British withholding is the second classic double-tax residue. Even where Article 18 reserves the pension to France, British tax may already have been deducted, because the payer applied the domestic code before the treaty relief arrived, because the pension straddles the arrival year, or because part of the payment is characterised differently in London. The order of operations is fixed. First, pursue the British side to the end: treaty relief at source for the future and a formal reclaim for the past, keeping the refusal or the payment stub either way. Second, declare the gross pension in France without deducting the British tax, then claim the Article 24 credit equal to the French tax attributable to that income, which the administration grants on sight of the British certificates. Third, where both administrations dig in and each claims the primary right, invoke the treaty’s mutual agreement procedure, the dialogue between the two tax authorities organised by Article 26 of the convention, while protecting the domestic deadlines in both countries. Never net the British tax off the declared French income: deducting foreign tax from the taxable base instead of crediting it against the computed tax understates the income for allowance thresholds, corrupts the social-charge band and still leaves the double charge alive.

Challenging a French assessment follows the standard administrative ladder, and each rung has strict time limits that run from the tax notice, so diary them on receipt of the avis d’imposition. Start with a written claim to the local tax office identifying the assessment, the pension lines disputed, the treaty article relied on and the credit computation, enclosing the British withholding certificates, the S1 and CPAM registration where social charges are disputed, and the scheme statements where arrears are concerned. If the administration maintains the charge in whole or in part, the dispute moves to the administrative court (tribunal administratif) for the tax and to the social-security court for the charges, where the two Court of Cassation decisions and the treaty paragraphs quoted in this article form the core exhibits. Throughout, keep the British and French files consistent: the pension figure declared in France, the figure on which British relief was granted and the figure on the scheme statements must reconcile to the euro, because the most frequent reason a credit is refused is not a point of law but a mismatch of amounts across the two files. A pension that is correctly classified under Article 18 or Article 19, fully declared with the 10 per cent allowance, shielded from social charges by a registered S1 where available, smoothed by the quotient where arrears spike it, and credited for any surviving British tax, is the complete compliant position, and every deviation from that chain is a concrete ground of challenge rather than a grievance.

Conclusion

A British resident drawing a UK private pension in France after Brexit holds a strong but paperwork-heavy position. The treaty gives France the taxing right over final-salary annuities and SIPP pension income through Article 18, reserves government-service pensions to the paying state through Article 19, and caps any surviving double charge through the Article 24 credit. France then taxes the declared pension with a 10 per cent allowance, exempts the S1 holder from social charges under the single-legislation principle, and softens arrears through the quotient, while the United Kingdom relieves at source once claimed. The failures that cost money are always the same: wrong treaty article for the payer, pension declared as salary, allowance missed, S1 unregistered at the CPAM, arrears taxed at the top slice without the quotient claim, and British withholding netted off instead of credited. Run the chain in order, keep both countries’ certificates reconciled, and challenge each surviving charge on its own legal ground within its time limit.

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