You moved to France with a Self-Invested Personal Pension, a workplace scheme, or a plan to transfer everything into a Qualifying Recognised Overseas Pension Scheme, and you assumed the British rules travelled with you. They do not. In the United Kingdom, you can usually take 25 per cent of your pension pot as a tax-free lump sum, draw the rest flexibly, and move funds between registered schemes with limited immediate tax consequences. Once you become fiscally domiciled in France, a different logic applies: France taxes you on your worldwide income, treats most pension payments as taxable pension income, and regards the celebrated 25 per cent tax-free lump sum as, in most cases, a fully taxable receipt. The transfer itself can also trigger a British overseas transfer charge of 25 per cent in defined circumstances. This guide explains, for a British reader living in France after Brexit, how your Self-Invested Personal Pension (a UK registered pension wrapper in which you choose the investments, universally shortened to SIPP), your Qualifying Recognised Overseas Pension Scheme transfer (a transfer to a pension scheme outside the United Kingdom that His Majesty’s Revenue and Customs recognises, shortened to QROPS), and your lump sum are taxed, which forms to file, which evidence to keep, and how to challenge a tax bill or a social-charge assessment that you consider wrong. Every French term is explained at first use. The law stated is the law in force on 5 October 2026.

I. How France taxes your British pension income and your lump sum after Brexit

A. How is my monthly SIPP income, drawdown and State Pension taxed when I live in France?

French tax residence is the starting point, and it is broader than many British newcomers expect. Under Article 4 A of the Code général des impôts, the French Tax Code, “Les personnes qui ont en France leur domicile fiscal sont passibles de l’impôt sur le revenu en raison de l’ensemble de leurs revenus.” In plain English: if your fiscal home (domicile fiscal) is in France, you are liable to French income tax on all of your income, wherever it arises. You have your fiscal home in France if your main home is here, if you spend most of the year here, if your principal economic interests are here, or if you work here. Most retired Britons who bought or rent a home in the Dordogne, Provence or Paris and spend their daily life here meet at least one of those tests. From that moment, your British pension income belongs on a French tax return, even if it is paid in pounds into a British bank account, even if British tax has already been deducted, and even if you consider yourself still British for every other purpose. Residence for immigration purposes under the Withdrawal Agreement and fiscal domicile for tax purposes are two different examinations, and passing one does not decide the other.

Once you are French-resident, the characterisation of the receipt matters. French domestic law is blunt. Under Article 79 of the Code général des impôts, “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. Il en est de même des prestations de retraite servies sous forme de capital.” Pensions therefore feed into your global taxable income (revenu global), and the same sentence expressly extends the rule to retirement benefits paid in capital form. A monthly SIPP drawdown, a flexi-access payment, an annuity bought with a British pot, a final-salary occupational pension, and the British State Pension all fall, as a starting point, inside that sentence. They are not treated as gambling winnings, not as exempt gifts, and not as capital that escapes income tax by its nature. They are pension income, and pension income is taxable.

The computation then follows the ordinary French method for pensions. Under Article 158, 5, a of the Code général des impôts, “Les pensions et retraites font l’objet d’un abattement de 10 % qui ne peut excéder 4 439 €.” Each pensioner in the household deducts 10 per cent from declared pensions, capped at 4,439 euros per household, with a minimum of 454 euros, before the progressive scale (barème) applies. The scale itself, set by Article 197 of the Code général des impôts, taxes slices of household income per part (the family-quotient unit) at rising rates. A British couple with two parts and 40,000 euros of combined annual pension income therefore does not pay a flat rate on 40,000 euros: each declares pensions net of the 10 per cent allowance, the household income is divided by two parts, the scale applies to each part, and the result is multiplied back. That mechanism often produces a lower bill than newcomers fear, but it also means that every extra euro of SIPP income pushes the top slice, and that the British personal allowance has no equivalent here. The 10 per cent allowance is automatic and needs no claim, but it only applies to amounts properly declared as pensions and retirement benefits, which is why the reporting boxes on the return matter so much.

The double tax treaty then decides which country has the primary right to tax, and how the other country relieves double taxation. The instrument is the Convention between France and the United Kingdom signed in London on 19 June 2008, published by Decree No. 2010-20 of 7 January 2010, which entered into force on 18 December 2009 and continues to apply after Brexit because tax treaties are independent of European Union membership. Its architecture is familiar: government-service pensions covered by the public-functions article generally remain taxable only in the paying State, while most private pensions and annuities are taxable only in the State of residence, subject to specific paragraphs that every file must read in full rather than from summaries. For a British retiree fiscally domiciled in France and receiving a private SIPP or occupational pension, the practical consequence is normally French taxation with a British exemption or repayment claim, rather than British deduction at source followed by a French top-up. State Pensions paid for private employment likewise normally fall to France when France is the residence State, while a pension paid for past British central-government service can remain taxable in the United Kingdom. The exact treaty article depends on the nature of each pension, so a household with three different pensions may have three different answers. Never merge them into one line.

The treaty also defines what counts as a covered tax on each side, and that definition is wider than income tax alone. In the Conseil d’État’s opinion on the treaty, the court recalled that under Article 2 of the 2008 Convention, “en ce qui concerne la France, tous les impôts perçus pour le compte de l’Etat ou de ses collectivités locales, quel que soit le système de perception, sur le revenu total ou sur des éléments du revenu” are covered, expressly including the generalised social contribution and the contribution for the repayment of the social debt. See Conseil d’État, 9th-10th chambers combined, 12 February 2020, No. 435907. That passage matters because British residents in France often assume that social charges (prélèvements sociaux, comprising the contribution sociale généralisée and the contribution pour le remboursement de la dette sociale) sit outside treaties. They do not sit outside this treaty as a matter of scope, but the elimination mechanism in Article 24 operates through a tax credit computed under precise conditions, and the Conseil d’État was asked exactly how that credit interacts with French social contributions on British-source income. The lesson for pensioners is concrete: declare the full pension for income tax and for social charges where due, compute the treaty credit strictly according to Article 24 rather than by instinct, and keep the British P60 (the end-of-year certificate of tax paid) and the French avis d’imposition (the assessment notice) side by side, because the credit will be examined against both.

Social charges deserve their own paragraph because they surprise almost every British household. French pensions borne by a French scheme and paid to a person covered by the French health system generally attract social charges at reduced pensioner rates with exemptions for modest incomes, while a British pension paid to a French-resident who is not covered by the French compulsory health scheme for that income can attract a different treatment. The coordination rules decide which State’s social-security legislation applies at all. The Conseil d’État recalled the principle that “les personnes qui relèvent du champ du règlement ne sont soumises qu’à la législation d’un seul Etat membre”, determined under Articles 11 to 16 of the coordination regulation. See Conseil d’État, 8th-3rd chambers combined, 25 October 2024, No. 473997. That decision concerned a Swiss reversion pension paid as a capital sum to a French-resident widow, but its reasoning on single legislation and on the charging of contributions on pensions from several States is routinely invoked in cross-border pension files. For a British pensioner in France after Brexit, the applicable coordination instrument is no longer the intra-Union regulation in its pure form but the Trade and Cooperation Agreement’s protocol on social-security coordination together with the bilateral position, and holders of a portable S1 healthcare certificate (the document by which the United Kingdom agrees to fund healthcare for certain pensioners living abroad) are in a materially different position from economically inactive residents affiliated in France. If you hold an S1 and are registered with the French caisse primaire d’assurance maladie (the local health fund, shortened to CPAM) on that basis, you may be exempt from part of the French social charges on the British pension, while remaining liable to income tax. If you are affiliated to the French system through French employment, self-employment, or residence-based coverage, the charge base can be wider. Establish your affiliation before you dispute the rate.

A final distinction within this first sub-part concerns the British State Pension and the annual uprating. The State Pension is a contributory benefit whose amount depends on National Insurance years, and it is paid gross from the United Kingdom. France taxes it as pension income when the treaty allocates it to France, with the same 10 per cent allowance. The British triple-lock uprating does not create a French exemption, and fluctuations in the pound do not create a deductible loss: France converts each payment at the rate applicable to the receipt and aggregates the euro amounts. Keep a monthly schedule with dates, sterling amounts, conversion rates, and the annual P60 figure, because the French administration will test the declared euro total against bank credits, and unexplained gaps invite a reassessment (redressement) with interest and penalties.

B. Is my 25 per cent tax-free lump sum still tax-free in France, and what does a QROPS transfer cost?

This is the question that generates the largest bills, because the British and French answers point in opposite directions. In the United Kingdom, a member of a registered pension scheme can normally take up to 25 per cent of the pot as a pension commencement lump sum free of British income tax, within the lump-sum allowance, and can then draw the balance flexibly. Many British advisers describe that lump sum as tax-free without qualification. In France, there is no general rule that mirrors that exemption. The starting point remains Article 79: retirement benefits paid in capital form feed into global taxable income. A 60,000-pound tax-free lump sum received in the year you are French-resident is therefore, as a starting point, 60,000 pounds of taxable pension income in France, converted to euros, before allowances and reliefs. The fact that His Majesty’s Revenue and Customs took nothing does not bind the French direction des finances publiques (the tax authority). The treaty does not generally recharacterise a lump sum paid out of a pension scheme as a non-taxable capital receipt; it allocates taxing rights over pensions, and France, as residence State for most private pensions, exercises them. Households that take the lump sum in the spring after moving to France in January learn this at the cost of a five-figure assessment.

French law then offers three possible reliefs, each with strict conditions, and the file must be tested against each in turn rather than assumed to qualify. The first is the ordinary 10 per cent allowance described above, which applies to the lump sum when it is taxed as pension income, within the same household cap. The second is the system of exceptional income (revenu exceptionnel) under Article 163-0 A of the Code général des impôts, which provides that “Lorsqu’au cours d’une année un contribuable a réalisé un revenu qui par sa nature n’est pas susceptible d’être recueilli annuellement” and the amount exceeds the average net income of the previous three years, the taxpayer may ask for the quotient system: add one quarter of the exceptional income to global income, compute the extra tax, and multiply by four. A one-off SIPP lump sum that dwarfs ordinary annual pensions is the textbook candidate for that provision, provided the amount genuinely exceeds the three-year average and the income by its nature is not annually recurring. The quotient does not exempt the lump sum; it softens the progressivity spike by preventing the entire capital from being taxed in the top slice. It must be claimed, it must be computed correctly, and the administration checks the three-year history, so keep those three avis d’imposition.

The third route is the flat-rate discharge levy (prélèvement libératoire) of Article 163 bis, and it is both the most attractive and the most frequently refused. Under Article 163 bis of the Code général des impôts, “Les prestations de retraite versées sous forme de capital imposables conformément au b quinquies du 5 de l’article 158 peuvent, sur demande expresse et irrévocable du bénéficiaire, être soumises à un prélèvement au taux de 7,5 %”, on the capital net of a 10 per cent reduction, where the payment is not split, and where the beneficiary proves that contributions during the accrual phase were deductible from taxable income or related to exempt income in the State that had the right to tax. The 7.5 per cent rate, plus social charges where due, can be dramatically lower than the marginal income-tax rate on a large lump sum, which is why British files invoke it so often. The Bordeaux court recently examined exactly such a claim for a large international-pension capital payment and tested each condition, including the deductibility proof and the administrative doctrine on the proportion of contributions to justify. See Administrative Court of Appeal of Bordeaux, 6th chamber, 3 December 2025, No. 23BX02970, where the court recorded “la somme de 411 091 euros de prestations de retraite versées sous forme de capital, provenant d’un contrat de pension internationale mis en place par l’employeur de M. C…”. The outcome in any individual file turns on its own contribution history, but the method is fixed: produce the scheme rules, the employer certificates, the contribution schedules, and the British tax treatment year by year, and map them to the French statutory test. A bare assertion that contributions were relieved in the United Kingdom does not suffice; the administration expects dated documents, and the court counts them.

The QROPS transfer itself raises a separate British question before any French question arises. Transferring a British registered pension to a recognised overseas scheme is, as the British government guidance explains, potentially subject to an overseas transfer charge, and the guidance warns that a 25 per cent overseas transfer charge can apply to the total amount transferred where no exclusion applies. See the official guidance on transferring to an overseas pension scheme. Exclusions exist, notably where the member and the scheme are in the same country or both in the European Economic Area, but a British pensioner resident in France transferring to a scheme outside those perimeters, or transferring to a scheme whose recognition lapses, can face the full charge deducted by the scheme administrator before the funds ever leave the United Kingdom. That charge is a British charge, distinct from French income tax on a later lump sum or drawdown from the receiving scheme. A transfer that is well-timed for British purposes can therefore still produce French tax on the benefits when they are later paid while you are French-resident, and a transfer that avoids the British charge can still fail the French deductibility history needed for the 7.5 per cent levy. Take advice on both sides before signing the discharge forms, and keep the transfer statement, the receiving-scheme recognition reference, and the charge calculation or exemption analysis with the French file: the French inspector will ask what moved, when, and what British tax was paid or relieved, because that history feeds directly into the Article 163 bis test.

Two common misunderstandings should be cleared at this stage. First, spreading a lump sum artificially across two calendar years to manufacture quotient eligibility or to stay below a threshold does not change its nature if the scheme rules show a single entitlement paid in instalments; the administration recharacterises split payments and the courts uphold it. The Article 163 bis levy expressly requires that the payment is not split (versement non fractionné), and the quotient requires income not annually recurring by nature. Second, leaving the lump sum in a British bank account and not remitting it to France does not shelter it: France taxes residents on worldwide income on an arising basis, not on a remittance basis. The taxable event is the payment by the scheme, not the transfer to France. Interest earned afterwards on the cash is a separate category of investment income, declared separately, and does not merge with the pension.

II. How to declare, evidence and challenge your British pension bill in France

A. Which forms do I file, which boxes do I tick, and which proof do I keep?

The declaration obligation is general and annual. Under Article 170 of the Code général des impôts, “toute personne imposable audit impôt est tenue de souscrire et de faire parvenir à l’administration une déclaration détaillée de ses revenus et bénéfices, de ses charges de famille et des autres éléments nécessaires au calcul de l’impôt sur le revenu”. For a British pensioner in France, that means three coordinated filings. First, the main return (déclaration No. 2042), where pensions and annuities are entered in the pensions boxes, with the 10 per cent allowance applied by the administration, not by you. Second, the foreign-income annexe (déclaration No. 2047), presented by the administration as the form to file when you are domiciled in France and have received income outside metropolitan France and the overseas departments. See the official Form 2047 notice on impots.gouv.fr. Each pension is entered with its country of origin, its euro amount, and the treaty credit claimed, so that the central return can compute French tax before credit and then subtract the credit exactly as Article 24 of the treaty allows. Third, the foreign-account return (déclaration No. 3916) for every British bank, investment, or pension-related account opened, held, used or closed during the year, including the SIPP cash account and any QROPS wrapper account, even where the pension income itself is reported elsewhere. The 3916 is a reporting obligation independent of taxability, with its own penalties, and British retirees are regularly penalised not for hiding pensions but for forgetting the account in which the pension landed.

The treaty-credit mechanics deserve patience because most reassessments arise here. Where the treaty allocates exclusive taxation to France, you declare the pension, France taxes it, and you claim repayment or exemption in the United Kingdom through the appropriate His Majesty’s Revenue and Customs double-taxation relief procedure, keeping the French assessment as proof of residence and taxation. Where the treaty allocates limited taxation at source with a French credit, you declare the gross British pension plus the British tax in the 2047, France computes its tax, and France grants a credit equal to the British tax but capped at the French tax attributable to that income. The credit is never a refund beyond French tax, never a cash payment, and never computed on social charges unless the treaty provision invoked expressly covers them. The Conseil d’État’s 2020 opinion dissected precisely this architecture for British-source income, asking whether the treaty’s credit language permits France to withhold the credit from French social contributions where no equivalent income tax exists in the United Kingdom, and whether progressivity preservation confines the credit to progressive taxes. See Conseil d’État, 12 February 2020, No. 435907. Practitioners should read that opinion in full before completing the 2047, because the boxes encode its answers: income taken into account for the effective rate (taux effectif) is not the same as income giving rise to a credit, and confusing the two either overpays or under-claims.

Evidence is what separates a file that survives a documentary check (contrôle sur pièces) from one that collapses. For regular pension income, keep for each year: the scheme P60 or equivalent annual statement, the twelve monthly payment slips or bank credits, a euro-conversion schedule, the French 2042 and 2047 filed, the British repayment claim and its outcome, the S1 certificate if you hold one with the CPAM registration, and any change-of-residence correspondence. For a lump sum, add: the scheme rules showing the entitlement, the lump-sum statement with the 25 per cent computation, the British tax-free confirmation, the three prior French assessments for the quotient test, the express and irrevocable option letter for the 7.5 per cent levy where claimed, and the full contribution history with employer certificates and British deductibility evidence for the Article 163 bis test. For a QROPS transfer, add: the transfer value statement, the receiving scheme’s recognised status at the transfer date, the overseas-transfer-charge calculation or exemption memorandum, and the post-transfer benefit statements. Store everything in both sterling and euros, in dated order, for at least the French limitation period plus the current year. When the inspector writes, the households that answer within thirty days with a complete bundleIndexed by year and cross-referenced to return lines are the households that obtain corrections without penalties.

Two household-level points complete this sub-part. First, the surviving spouse’s position differs from the member’s position. A reversion pension (pension de réversion) paid as a capital sum after a death is tested under the same capital-versus-income logic, but the social-charge analysis can diverge because the beneficiary’s own affiliation and the deceased’s scheme history both matter. The 2024 Conseil d’État decision on a Swiss reversion capital payment illustrates how courts combine the single-legislation principle with the domestic charge base, and its method transfers readily to British reversion capital paid to a French-resident widow or widower. See Conseil d’État, 25 October 2024, No. 473997. Second, where British readers also hold French pension rights from past French employment, the French and British pensions are aggregated for the progressive scale even when each is computed separately for credits. The aggregation is what preserves progressivity, and it is why omitting a small British pension to simplify the return is both an offence and arithmetically pointless: the administration reconstructs worldwide income from exchange-of-information data and then applies the higher rate to the income it already knew.

B. How do I challenge a reassessment, a refused 7.5 per cent levy, or a social-charge bill?

French tax disputes follow a fixed ladder, and each rung has a deadline that extinguishes the claim if missed. The first step is almost always the administrative claim (réclamation contentieuse) sent to the tax office that issued the assessment, setting out the facts, the legal basis, and the precise relief sought: discharge (décharge), reduction (réduction), or restitution of a credit. Attach the return, the assessment, the treaty article relied upon with its paragraph, the P60 and conversion schedule, and, for a lump sum, the quotient computation or the Article 163 bis option with its contribution bundle. The administration must answer; silence after six months is an implied rejection that opens the next rung. The second step is the administrative court (tribunal administratif) in whose district you live, seised within two months of the express or implied rejection. The court examines the file de novo on the tax law, but it cannot invent evidence you never filed: the contribution history absent at the claim stage remains absent at the hearing unless you regularise it through proper exhibits. The third step, on points of law, is the administrative court of appeal (cour administrative d’appel) and then the Conseil d’État, whose decisions on treaty credits and on capital-pension charging now form the backbone of this field.

Three lines of challenge recur in British pension files, and each has its own proof burden. The first line attacks the characterisation: the administration taxed as an ordinary pension annuity what was in substance a capital benefit eligible for the quotient or the 7.5 per cent levy, or it refused the quotient on the ground that the income was annually recurring. Here the scheme rules and payment history decide. A flexi-access drawdown taken every month for three years is not a one-off capital payment by nature; a single crystallisation lump sum paid once on retirement is. The Bordeaux file shows the administration testing the international-pension capital against the Article 163 bis conditions line by line, including the doctrine on the proportion of contributions to document. See CAA Bordeaux, 3 December 2025, No. 23BX02970. Mirror that discipline in your claim: identify each contribution year, state who paid, state the British tax treatment with the document reference, and explain why the French test is met. The second line attacks the treaty credit: the administration denied the credit, capped it wrongly, or applied it to the wrong tax. Here the treaty text, the 2047 lines, and the British tax certificate decide. Quote the paragraph, show the arithmetic, and reconcile the British certificate to the French euro amount. The 2020 opinion is your map. See Conseil d’État, 12 February 2020, No. 435907. The third line attacks social charges: the administration charged full social contributions on a British pension where European coordination or the S1 position excluded them, or it charged them on a capital sum that domestic law treats differently. Here affiliation evidence decides: S1 certificate, CPAM attestation, certificate of coverage, and the scheme’s classification of the payment. The 2024 decision is your framework. See Conseil d’État, 25 October 2024, No. 473997.

Withholding at source (retenue à la source) is the mirror image that British leavers sometimes meet when they return to the United Kingdom but keep French-source pensions. Under Article 182 A of the Code général des impôts, French-source salaries, pensions and life annuities paid to persons not fiscally domiciled in France attract a withholding, computed on the net amounts under income-tax rules excluding actual professional expenses. A British reader who leaves France and becomes exclusively British-resident should therefore expect French payers to switch from the resident declaration system to the non-resident withholding system, and should claim treaty relief in the residence State rather than asking the French payer to ignore the statute. Keep the departure evidence: deregistration, new lease or purchase, shipping records, and the first British self-assessment return. The year of departure is frequently taxed in both countries on different bases before the credits settle it, and only dated residence proof resolves the overlap.

Practical timing advice closes this sub-part. Do not take the 25 per cent lump sum in the calendar year of arrival without modelling French tax first: arriving in November and crystallising in December concentrates the capital on top of a full year of progressivity mechanics and can forfeit the quotient comparison. Do not transfer to a QROPS in the weeks before taking benefits without confirming the receiving scheme’s recognised status on the exact transfer date and the overseas-transfer-charge exclusions in writing. Do not file the 2047 from memory: reconcile every pound to a bank credit and every euro to a conversion slip. And do not ignore a reassessment letter because it is in French: the claim deadline runs from notification, the language does not suspend it, and a late claim fails even where the substantive argument was excellent. Readers who want the succession counterpart to this pensions analysis, on choosing English law for a French house and protecting children within the reserved-share rules, will find it in the firm’s companion guide on British wills and French houses under the EU Succession Regulation.

Conclusion

Your British pension does not become a different asset when you settle in France, but it enters a different tax system with its own vocabulary and its own proof culture. France taxes your worldwide pensions once you are fiscally domiciled here, allows a 10 per cent allowance within a cap, applies the progressive household scale, and grants treaty credits strictly as the Convention provides. Your 25 per cent British tax-free lump sum is normally taxable in France, with the quotient system and, where the contribution history supports it, the 7.5 per cent flat-rate levy as the two structured mitigations, each claimed expressly and evidenced in full. Your QROPS transfer is a British charge event first and a French tax-history event second, and both must be documented before the transfer, not reconstructed afterwards. File the 2042 with the 2047 and the 3916, keep sterling-to-euro schedules with P60s and assessments, establish your health-system affiliation before disputing social charges, and challenge any reassessment through the claim-to-court ladder within its deadlines. Handled in that order, a British private pension in France is not a trap but a manageable file: fully declared, correctly relieved, and capable of withstanding a documentary check.