You are British, you draw a UK State Pension, and you live in France, or you plan to settle in the Dordogne, in Brittany, in Paris or in the south after Brexit. Two questions dominate every conversation with an adviser: where do you pay tax on that pension, and how do you get healthcare without an employer. The answers sit in two different bodies of rules that do not speak to each other. Tax is governed by French domestic law and by the France-United Kingdom double taxation convention signed in London on 19 June 2008, still in force after Brexit. Healthcare is governed by the French Social Security Code, by the Withdrawal Agreement and the EU-UK Trade and Cooperation Agreement for coordination, and in practice by the local health fund, the Caisse Primaire d’Assurance Maladie, known as the CPAM, which registers your rights. Confusion is costly. Some new arrivals keep paying UK tax on a pension that France alone may tax, or they declare nothing in France because the pension is paid from Newcastle. Others arrive with a UK-issued S1 form, which is the portable document that shifts the cost of your French healthcare to the United Kingdom, and never register it, so the CPAM treats them as uninsured. Others assume the S1 covers everything, including the part of French medical bills that remains payable by the patient, known as the ticket modérateur, and discover the gap at the pharmacy or the hospital. This guide explains, for a British reader with no French legal training, where your UK State Pension is taxed when you are French resident, which pensions remain taxable in the United Kingdom under the government-service exception, how the S1 route differs from the general French universal health cover known as the Protection Universelle Maladie, usually called PUMA, and what to do when the CPAM refuses registration or the tax office sends a bill you consider wrong. Every French term is explained at first use. Every decisive proposition is tied to the exact statutory wording and to official sources you can open yourself.

I. Where do you pay tax on your UK State Pension when you retire in France after Brexit?

A. Are you French tax resident and does France alone tax your UK State Pension under Article 18?

The first step has nothing to do with the pension itself. France taxes its residents on worldwide income, and the treaty then allocates the right to tax between the two States. Your residence therefore decides everything. Article 4 B of the French General Tax Code, the Code général des impôts, provides that “Sont considérées comme ayant leur domicile fiscal en France au sens de l’article 4 A : a. Les personnes qui ont en France leur foyer ou le lieu de leur séjour principal”. The provision is available at Article 4 B of the Code général des impôts on Légifrance. In practice the French tax administration, the Direction Générale des Finances Publiques, applies three alternative tests: your home or principal place of stay is in France, you carry on a professional activity in France, or the centre of your economic interests is in France. Meeting any one of them makes you French tax resident in domestic law, subject to the treaty tie-breaker if both States claim you. Readers who split the year between Kent and the Charente should read our detailed explanation of how the France-United Kingdom tie-breaker decides dual tax residence and how to challenge a wrong assessment, which sets out the permanent-home, centre-of-vital-interests and habitual-abode sequence that départages competing claims.

Once French residence is established, Article 79 of the same Code brings the pension into the French base. It states that “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 text is published at Article 79 of the Code général des impôts on Légifrance. The second sentence adds that retirement benefits paid as a lump sum are treated the same way. Article 158 then confirms the worldwide logic for residents, providing that assessment follows domestic rules “sans qu’il y ait lieu de distinguer suivant que ces revenus ont leur source en France ou hors de France”, at Article 158 of the Code général des impôts on Légifrance. A UK State Pension paid by the Department for Work and Pensions into a British bank account is therefore within the French taxable base when you live in France, even though the source of payment is British. The declaration is made on the main return, form 2042, with foreign pension income detailed on the supplementary form 2047, and the treaty credit mechanism described below avoids double payment.

The treaty then answers the allocation question, and for an ordinary State Pension the answer is normally exclusive taxation in the residence State. Article 18 of the 2008 France-United Kingdom convention, whose official English text is published by the British government, provides that pensions and similar remuneration paid for past employment to a resident of one of the two States are taxable only in that State of residence. The full convention is available at the 2008 United Kingdom and France Double Taxation Convention in force on GOV.UK. A British national who is resident in France within the meaning of the treaty and who receives a UK State Pension for past private-sector employment is therefore taxable only in France on that pension. The United Kingdom gives up its taxing right. France taxes, and the UK should not. That is the mirror image of the British resident with a French pension, who is taxable only in the United Kingdom. The rule covers the basic State Pension, the new State Pension for those reaching pension age after April 2016, and the earnings-related additions such as the former State Second Pension and SERPS, because all are paid in consideration of past employment or past contributions treated as such. It does not depend on where the pension is paid, in which currency, or whether the pensioner holds British nationality. Residence plus past-employment characterisation is enough.

Two practical consequences follow. First, the pensioner who has just moved must tell both sides. On the French side, the pension is declared each spring for the previous calendar year, converted into euros at the annual rate published by the tax administration, with the 10 per cent automatic deduction for pension income capped by statute, plus the applicable social charges analysis discussed in Part I.B. On the British side, a pension that is taxable only in France can be paid without UK withholding once HM Revenue and Customs, known as HMRC, has issued a no-tax code under the treaty claim procedure, usually form France-Individual. Without that step, emergency tax may continue to be deducted at source and the pensioner must reclaim it, which explains many first-year double-payment complaints. Second, treaty interpretation follows a strict method that taxpayers can invoke against loose reasoning by either administration. The Cour de cassation, the French supreme court for civil and tax matters, recalled in its judgment of 11 February 2026, appeal number 23-14.305, published at Cour de cassation, commercial chamber, 11 February 2026, appeal 23-14.305, that a lower court had reasoned “En se déterminant ainsi, sans rechercher, comme il lui incombait, si la Convention s’appliquait au prélèvement sur les trusts prévu à l’article 990 J du code général des impôts”. The court quashed the decision for failure to verify whether the convention actually covered the levy and whether a later charge was of an identical or analogous nature. The passage matters beyond trusts. It states the general discipline for treaty cases: identify the treaty article, verify its personal and material scope, and verify that the domestic charge falls within the taxes the convention covers. A British pensioner who is told that Article 18 does not apply to a particular addition, supplement or back payment should require the administration to show its analysis under the same discipline, article by article, rather than accept a general assertion.

A further domestic safeguard concerns French-source pensions paid to persons who are not French resident. Article 182 A of the General Tax Code 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”, at Article 182 A of the Code général des impôts on Légifrance. Article 164 B defines the French-source perimeter, opening with “Sont considérés comme revenus de source française”, at Article 164 B of the Code général des impôts on Légifrance. These provisions matter at the boundaries of the present guide. A British pensioner who leaves France mid-year, or who spends a transitional year straddling both States, may receive a French pension element, for example a small French basic pension from the CARSAT network for past work in France, while no longer French resident. That French-source pension can attract withholding at source, with treaty relief available on claim. Conversely, a UK State Pension paid to a French resident is not French-source employment income of this kind, so Article 182 A is not the charging provision. The French resident declares under Articles 79 and 158 and claims exclusive French taxation under Article 18 of the treaty. Keeping the two mechanisms separate avoids the common error of applying withholding rates to a UK pension that belongs in the residence-only article.

B. Which pensions stay taxable in the United Kingdom, what happens to frozen rates, and how is double taxation relieved?

Article 18 is the general rule, but Article 19 of the same convention carves out government service, and British retirees in France meet this exception more often than they expect. Teachers in local-authority schools, National Health Service staff, civil servants, police officers, members of the armed forces and employees of other statutory bodies may have part or all of their pension rights attached to public employment. Article 19, paragraph 2, states that pensions paid by a State or its local authorities for government service are taxable only in that paying State. The official text continues with the nationality exception: where the pensioner is a resident and a national of the other State without also being a national of the paying State, the pension is taxable only in that other State. The full wording is on the same official page at the 2008 United Kingdom and France Double Taxation Convention in force on GOV.UK. In plain terms, a UK civil-service pension paid to a British national who retires in the Dordogne remains taxable only in the United Kingdom. France must exempt it, while taking it into account for the progressive rate if domestic law so provides under the treaty credit method. The same pension paid to a French national who worked for the British administration and retired in France, without British nationality, is taxable only in France. Nationality therefore flips the result within Article 19, whereas it is irrelevant under Article 18. Mixed careers must be apportioned. A nurse with twenty years in the National Health Service and ten years in a private clinic has two pension streams that may fall under different articles, and the payslips, pension statements and scheme booklets should be kept to prove which stream belongs where, because the French tax office will ask for documentary proof before granting exemption for the public-service part.

Three further points complete the tax picture. First, the United Kingdom does not uprate, which means increase annually, the State Pension for all pensioners abroad. France is on the list of countries where uprating continues, so a British pensioner resident in France receives the annual triple-lock increase, unlike a pensioner in Australia or Canada whose pension is frozen. The distinction matters because some advisers still repeat the frozen-pension warning for France, which is wrong. Entitlement, age and amount remain governed by British law and administered by the International Pension Centre in Wolverhampton, while taxation of the amount once paid is governed by the analysis above. The pension can be paid into a French bank account in euros or into a British account in sterling. The payment channel does not change the treaty result, though exchange fees and the annual conversion rate for the French return affect the net position. Second, French social charges, known as prélèvements sociaux, which comprise the general social contribution called the Contribution Sociale Généralisée and the solidarity levies, apply differently to treaty-exempt and treaty-taxable income and to pensioners affiliated to a compulsory health scheme in the European Union. A British pensioner registered in France through an S1, described in Part II, is generally treated as insured in another European scheme for the charge analysis and may be liable to the solidarity levy rather than the full contribution on certain income, but the position depends on the income category and the year, so each assessment should be checked line by line rather than assumed. Third, double-taxation relief where both States have taxed follows Article 24 of the convention, the elimination-of-double-taxation article on the same official page, which grants a tax credit in the residence State for tax properly levied at source, limited to the residence-State tax attributable to the same income. The Cour de cassation judgment cited above reinforces that credit claims must be reasoned impost by impost. Keep the UK P60, the French avis d’imposition, which is the printed tax assessment notice, and the proof of any UK withholding, then claim the credit on the French return with the treaty article number stated in the attached note. Where the administration refuses the credit or taxes a pension that the treaty reserves to the United Kingdom, the remedy is a formal claim, called a réclamation contentieuse, to the local tax office within the statutory time limit, followed by appeal to the administrative court, the Tribunal administratif, if the refusal is maintained. The claim should quote Article 18 or Article 19 paragraph 2 verbatim, attach residence evidence such as the French tax notice, utility bills and the Withdrawal Agreement residence permit where held, and attach the pension paying-authority letter showing the nature of the employment that generated the pension.

A word on proof of residence duration, because pensioners who travel face the six-month argument. In a different social-benefit context, the second civil chamber of the Cour de cassation held, on 15 May 2025, appeal number 23-12.362, published at Cour de cassation, second civil chamber, 15 May 2025, appeal 23-12.362, that “les périodes de résidence retenues pour l’année 2016 représentaient une durée totale de 216 jours de présence en France de l’allocataire, soit pendant plus de six mois”, before drawing the legal consequences for the residence condition of the benefit. The passage is cited here only for its factual method: administrations count days, and 216 days exceeds six months. British pensioners should keep the same discipline. Boarding passes, ferry bookings, health-reimbursement statements known as relevés de soins, and bank-card records establish where the 183 days, the six-month threshold and the principal-stay test of Article 4 B fall. The treaty tie-breaker and the domestic principal-stay test both reward the person who can document daily life, not the person who asserts it.

II. How does healthcare work for a British pensioner in France: S1, PUMA and CPAM registration?

A. When does the UK-issued S1 give you French healthcare without joining PUMA?

Healthcare in France for a British pensioner follows one of two routes, and choosing the wrong queue explains most refusals. The first route is the S1, which is the portable document issued by the United Kingdom that certifies that the UK pays for your state healthcare while you live in France. The second route is PUMA, the French universal cover for residents who are not otherwise insured. The S1 route takes priority wherever it is available, because France does not insure through PUMA a person whose healthcare costs are already borne by another State under coordination rules. The British government guidance for pensioners states that a resident in France who receives a UK State Pension or an exportable benefit may be entitled to state healthcare paid for by the United Kingdom, and should register the S1 with the local CPAM, at healthcare for United Kingdom nationals living in France on GOV.UK. The French service-public portal mirrors the instruction for newly arrived foreigners holding a portable document, directing S1 holders to register rather than apply for PUMA, at health insurance for a foreigner settling in France on service-public.fr. The operational detail, including the registration form and the liaison body known as the Centre des Liaisons Européennes et Internationales de Sécurité Sociale, usually called the Cleiss, is set out at the S1 registration guidance on cleiss.fr. Dependants are covered through the same logic: once the pensioner registers an S1, a non-working spouse and dependent children can be attached as ayants droit, which means dependants drawing rights from the insured person, without a separate contribution record.

The statutory anchor for the French side of this coordination is Article L160-1 of the Social Security Code, the Code de la sécurité sociale, which provides that “Toute personne travaillant ou, lorsqu’elle n’exerce pas d’activité professionnelle, résidant en France de manière stable et régulière bénéficie, en cas de maladie ou de maternité, de la prise en charge de ses frais de santé”, at Article L160-1 of the Code de la sécurité sociale on Légifrance. The scope of that care is defined by Article L160-8, which opens with “La protection sociale contre le risque et les conséquences de la maladie prévue à l’article L. 111-2-1 comporte”, before listing general and specialist medicine, dental care, pharmacy, laboratory examinations, hospitalisation and related treatment, at Article L160-8 of the Code de la sécurité sociale on Légifrance. An S1 holder receives this same basket of care from the French system, while the cost is recharged to the United Kingdom between institutions. Registration is therefore not a courtesy. It is the act that opens the French reimbursement record, the droits, and that generates the Carte Vitale, which is the green plastic health card used at every surgery and pharmacy, and the attached mutuelle discussion below. In practice the file is lodged at the CPAM of the place of residence with the original S1, proof of identity, proof of address, birth certificate with official translation where required, bank details known as the Relevé d’Identité Bancaire, and the Withdrawal Agreement residence permit where held. The CPAM records the S1, affiliation follows without a waiting period linked to three months of presence, and reimbursements flow at French rates. The pensioner continues to pay the patient share, the ticket modérateur, unless a private top-up policy, called a mutuelle or complémentaire santé, covers it. The S1 does not create a French pension, does not exempt the UK pension from French tax, and does not replace the European Health Insurance Card for travel. It is strictly a healthcare-cost instrument, and presenting it as anything wider invites refusal.

Eligibility for the S1 as a pensioner turns on British issuing rules, not on French discretion. The United Kingdom issues an S1 to a person who is resident in France and who draws a UK State Pension, and to certain recipients of exportable benefits such as long-term incapacity benefits, as well as to posted workers and frontier workers under separate provisions. The pensioner applies through the NHS Business Services Authority overseas-healthcare service or the International Pension Centre contact route, receives the paper S1 by post, and must not lose the original, because the CPAM keeps a copy and returns the original with its stamp. Timing matters. Apply before the move where possible, or immediately after arrival, because medical costs incurred before registration are reimbursed only once rights are opened, and hospitals will ask for an attestation de droits, which is the printed proof of open health rights, before scheduling non-urgent treatment. British pensioners who worked in France as well as in the United Kingdom, and who draw a French pension alongside the UK pension, are normally affiliated in the State of residence through the French pension, and the S1 route may not be offered, since France becomes the competent State for someone whose French pension record makes France responsible. Where both pensions exist, ask the CPAM and the Cleiss in writing which State is competent before assuming the UK document governs, and keep the written reply with the health file.

B. When do you fall back on PUMA, what does the CPAM check, and how do you challenge a refusal or a tax bill?

Where no S1 is available, the fallback is PUMA, and the CPAM examines two cumulative conditions: stable residence and lawful stay. The stability limb is set by Article L111-2-3 of the Social Security Code, which refers to “les conditions d’appréciation de la stabilité de la résidence et de la régularité du séjour”, at Article L111-2-3 of the Code de la sécurité sociale on Légifrance. The implementing regulation, Article R111-2, provides that “sont considérées comme résidant en France de manière stable les personnes qui ont leur foyer ou le lieu de leur séjour principal sur le territoire métropolitain”, at Article R111-2 of the Code de la sécurité sociale on Légifrance. In practice the funds require three months of continuous presence before opening PUMA rights for an inactive newcomer, proven by rent receipts, utility bills, bank statements showing daily spending in France, and the long-stay visa or residence permit. The lawfulness limb means holding a valid right to stay: Withdrawal Agreement permit for protected Britons, long-stay visitor visa with the validation vignette for new retiree arrivals, or another applicable titre de séjour, which is the French residence permit. An early application filed days after arrival, or a file with a passport stamp but no visa validation, will be refused on stability or regularity grounds even where the medical need is genuine.

A recent judgment illustrates how strictly tribunals enforce this sequence. On 17 March 2026 the social chamber of the Lille judicial court, case number 25/01909, published at Tribunal judiciaire de Lille, social chamber, 17 March 2026, case 25/01909, upheld a CPAM refusal of PUMA affiliation for a European jobseeker who had applied shortly after arrival. The court held that “il ressort des dispositions susvisées que la situation de Mme [B] n’ouvrait pas droit au bénéfice de la protection universelle maladie (PUMA) à la date du 5 janvier 2025.” The facts differ from a British pensioner, since the claimant was an uninsured jobseeker rather than a pensioner, but the legal method transfers directly: the tribunal verified the residence and activity situation at the exact application date, applied Articles L160-1 and R111-2, and confirmed the refusal because the conditions were not met on that date. British retirees should draw three lessons. First, the assessment date is the application date, so reapply once the three months are complete rather than litigating a premature file. Second, inactivity alone does not open PUMA where another cover, such as an S1, exists or where stay conditions fail. Third, the judgment confirms the refusal, which means the remedy is a fresh complete file or a reasoned appeal, not continued treatment on an unopened right. A parallel illustration comes from the Cour de cassation on 25 September 2025, appeal number 23-15.880, published at Cour de cassation, second civil chamber, 25 September 2025, appeal 23-15.880, which approved totalisation of insurance periods across States for pension calculation where the applicable coordination instrument allowed it, recalling that foreign periods count only as the instrument and domestic law permit. The same discipline governs S1 and PUMA: coordination first, domestic fallback second, never both at once.

Costs and remedies close the picture. PUMA affiliation for a pensioner without earned income may attract the subsidised contribution known as the Cotisation Subsidiaire Maladie where worldwide income exceeds a statutory threshold, calculated on the income tax return data transmitted to the health fund. An S1 holder does not pay that contribution on the same basis, which is one more reason to secure the S1 where eligible before accepting PUMA billing. Low-income pensioners affiliated through either route may also claim the complementary solidarity cover, the Complémentaire Santé Solidaire, whose statutory base states that “Les personnes mentionnées à l’article L. 160-1 ont droit à une protection complémentaire en matière de santé”, at Article L861-1 of the Code de la sécurité sociale on Légifrance, with means-tested free or subsidised cover for the ticket modérateur, dental and optical care. For temporary stays in the other State, Article L160-3 adds that “Lorsqu’ils résident à l’étranger et n’exercent pas d’activité professionnelle, bénéficient, lors de leurs séjours temporaires en France, de la prise en charge de leurs frais de santé prévue à l’article L. 160-1”, for holders of a French old-age pension and allied beneficiaries, at Article L160-3 of the Code de la sécurité sociale on Légifrance. A British pensioner with a small French pension who returns for summer visits should therefore check whether temporary-stay cover flows through the French record rather than through travel insurance alone.

When the CPAM refuses S1 registration or PUMA affiliation, the challenge follows a fixed ladder. First, file the amicable appeal to the fund, called the Commission de Recours Amiable, within two months of the refusal, attaching the missing proof: original S1, visa validation, three months of presence evidence, or the competence letter from the Cleiss. Second, on express or implied rejection, bring the case before the social chamber of the judicial court, the Pôle social of the Tribunal judiciaire, within two months, with the refusal letter, the complete health file, and a dated chronology of presence. Ask the tribunal to verify the exact application-date conditions under Articles L160-1, L111-2-3 and R111-2, following the Lille method, and to order registration with retroactive opening of rights where the evidence supports it. Third, for tax disputes, file the contentious claim to the tax office with the treaty article quoted verbatim, then appeal to the Tribunal administratif, keeping every deadline stamped. In both lanes, never rely on telephone assurances. Written reasons, written replies and stamped receipts decide these files. Keep copies of the S1, the CPAM attestation once issued, the P60, the French tax notice, and the residence permit in one folder, paper and scanned, because the same documents will be requested twice, once by the health fund and once by the tax office, and consistency between the two files is itself evidence of genuine French residence.

Conclusion

A British pensioner who settles in France after Brexit lives under two allocation rules that point in the same direction: be taxed where you really live, and be insured by the State that really bears the cost. For an ordinary UK State Pension, Article 18 of the 2008 convention reserves taxation to France once French residence is established under Article 4 B and declared under Articles 79 and 158, with Article 19 preserving United Kingdom taxation only for the government-service pensions it lists, subject to the nationality proviso. For healthcare, the S1 route gives direct registration with the CPAM at French clinical standards with costs recharged to the United Kingdom, while PUMA receives only those residents who are stably and lawfully present and not already covered elsewhere, under Articles L160-1, L111-2-3 and R111-2, with the Lille judgment of 17 March 2026 showing how tribunals test the application-date conditions. Put the S1 on file first where eligible, complete the three-month PUMA file where it is not, declare the pension in France with the treaty article stated, claim the Article 24 credit where source tax was properly levied, and challenge refusals through the amicable commission and the competent court with dated documentary proof. That sequence turns an anxious first year into an orderly file that both the CPAM and the tax office can accept.