You have done the hard part. You sold up or kept a foothold in Britain, you sorted your long-stay visa and residence card on arrival (carte de séjour, the permit that lets a British citizen live in France after Brexit), and you now wake up to French light every morning. Then the first French tax return lands on the doormat, and a simple question turns stressful: Britain already taxes your pension at source, France now asks you to declare it, and you cannot tell whether you are about to pay twice on the same money. This guide answers that question for every kind of British pension — the UK State Pension, a former employer’s workplace pension, a personal pension such as a SIPP (Self-Invested Personal Pension, a UK retirement pot you manage yourself), a tax-free lump sum, and a transfer to a QROPS (Qualifying Recognised Overseas Pension Scheme, a pension scheme outside the UK that HMRC, the British tax authority, recognises for transfers). The short answer is that once you are tax resident in France, France normally has the exclusive right to tax your British pensions, with one major exception for former government service. The longer answer — how to declare, what allowance to claim, how the credit mechanism wipes out double taxation, and how to appeal if the bill is wrong — is what follows.
I. Which country taxes your British pension once you live in France
A. State, workplace and private pensions: France taxes you as a French resident
Everything starts with residence, because residence decides which country is allowed to tax you. French domestic law treats you as having your tax home (domicile fiscal) in France as soon as you meet any one of three tests: « Les personnes qui ont en France leur foyer ou le lieu de leur séjour principal » — people whose household (foyer, where your family permanently lives) or principal place of stay is in France — plus people working in France and people with the centre of their economic interests there. In practice, a British retiree who lives year-round in the Dordogne with their spouse, keeps their main bank activity there and visits the grandchildren in Manchester for a few weeks, meets the first test without any doubt. Once that test is met, France taxes your worldwide income, including pensions paid from Britain.
That French claim would create double taxation if Britain taxed the same pensions in parallel, and this is exactly what the double tax treaty signed in London on 19 June 2008 exists to prevent — the convention published in France by decree on 7 January 2010 (the treaty text is reproduced in the official France–UK treaty publication). Its pensions article is admirably short: Article 18 of the France–UK treaty provides that, subject to the government-service rule in Article 19(2), pensions and similar payments for past employment received by a resident of one state are taxable only in that state. Read that rule twice, because it settles most cases. If you are a resident of France, pensions and similar payments for past employment are taxable only in France. Britain must step aside. This covers the UK State Pension, a defined-benefit workplace pension from a private-sector employer (a pension that pays a promised amount based on salary and years of service), and income drawn from a personal pension or SIPP — all of them are pensions « au titre d’un emploi antérieur », paid for earlier work.
Two practical consequences follow. First, if HMRC has been deducting British tax at source from a pension that the treaty reserves to France, that deduction is not the last word: the treaty gives France the exclusive right, and overpaid British tax can be reclaimed from HMRC under the treaty procedure — the British government explains the non-resident position on its tax if you live abroad pages, and State Pension recipients will find the residence position confirmed in the official guidance on claiming the State Pension abroad. Second, on the French side, the pension must be declared and taxed under French rules, because the treaty removes Britain but never removes France. French domestic law is explicit: « 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 join your overall taxable income (revenu global), whether paid monthly or as capital.
French law then softens the blow with a standard allowance (abattement, a fixed reduction applied before the rate scale). « Les pensions et retraites font l’objet d’un abattement de 10 % qui ne peut excéder 4 439 €. » Every pensioner household deducts 10 per cent of its pensions, capped at 4,439 euros in total, and the same article adds the floor: « L’abattement indiqué au deuxième alinéa ne peut être inférieur à 454 €, sans pouvoir excéder le montant brut des pensions et retraites. » The balance is taxed at the progressive household scale (quotient familial, the system that divides household income into parts, usually two for a couple). The current scale provides: « L’impôt est calculé en appliquant à la fraction de chaque part de revenu qui excède 11 600 € le taux de : – 11 % pour la fraction supérieure à 11 600 € et inférieure ou égale à 29 579 € ; – 30 % pour la fraction supérieure à 29 579 € et inférieure ou égale à 84 577 € ; – 41 % pour la fraction supérieure à 84 577 € et inférieure ou égale à 181 917 € ; – 45 % pour la fraction supérieure à 181 917 €. »
A worked illustration makes this concrete. Take a couple, both British, French tax resident, receiving 22,000 euros of UK State Pensions and 18,000 euros of private workplace pensions between them — 40,000 euros in total. Deduct the 10 per cent allowance, 4,000 euros, leaving 36,000 euros of taxable pension income. Divided into two parts, that is 18,000 euros per part; the slice above 11,600 euros (6,400 euros) is taxed at 11 per cent, about 704 euros per part, roughly 1,408 euros for the household before any reductions or credits. The figures move with exchange rates and each year’s scale, but the method never changes: declare everything, deduct the allowance, apply the scale to the parts. And because the treaty reserves these pensions to France, no British tax should remain on top — if it does, the credit and reclaim machinery described in part II removes it.
B. The exception that changes everything: pensions for former government service stay British
Article 18 opens with a reservation for the government-service rule in Article 19(2) — and that reservation is the trap most British retirees fall into. Pensions paid for government service (pensions de la fonction publique) follow the opposite logic. The treaty provides that pensions paid by one state or its local authorities (or, for France, its public-law bodies), directly or from funds they have set up, for services rendered to that state or body, are taxable only in that state — unless the pensioner lives in the other state, holds that other state’s nationality, and does not also hold the first state’s nationality, in which case only the state of residence taxes the pension (Article 19(2) of the France–UK treaty). In plain terms: a pension paid by the British state or a local authority for work done for that state remains taxable only in Britain — unless the pensioner lives in France, holds French nationality, and does not hold British nationality at the same time, in which case France alone taxes it.
Who is concerned? Former civil servants, local-authority officers, police officers and firefighters whose pension is paid out of public funds for service to the state. The decisive question is always who pays and for what service: a pension paid by a public body for government service points to Britain; a pension from a privatised employer, even one that used to be public, points back to Article 18 and France. Check the paying body named on your pension payslip (P60, the British end-of-year statement of pay and tax) and your leaving papers before assuming anything, because this single classification decides the whole treatment. Where a household mixes both kinds — say, a former local-authority officer married to a former shop manager — each pension follows its own article, and the return must keep them apart: the government-service pension is declared in France but neutralised by a tax credit equal to the French tax on it, while the private pension is taxed normally. The credit mechanism is not a favour from the tax office; it is the treaty’s own method in Article 24, and the Conseil d’État, France’s highest administrative court, has fixed how it works in a 2020 opinion on this very convention: the credit is due even where the income suffered no real taxation abroad, because « cette condition n’exige pas que les revenus en cause aient été soumis à une imposition effective », and more precisely « la condition prévue à l’alinéa (i) du a) du paragraphe 3 de l’article 24 de la convention doit être regardée comme satisfaite s’il est établi par le résident de France qu’il a déclaré les revenus en cause au Royaume-Uni, parce que ces revenus étaient compris dans la base de l’un des impôts énumérés au a) du 1 de l’article 2 de la convention, alors même qu’il n’aurait acquitté dans cet Etat aucun impôt à raison de ces revenus. » Declare the income in Britain within the scope of a covered tax, even if no British tax is actually payable, and the French credit follows.
One smaller group enjoys an even better position. War pensions and injury pensions linked to military service can be fully exempt. The convention provides that British injury and disability pensions payable under the schemes it lists — including service in the armed forces and the 1939 emergency-injuries legislation — are exempt from French tax provided they are exempt from British tax: the treaty grants the exemption whatever the pensioner’s nationality, on condition the pension is exempt across the Channel (war-pension exemption in the France–UK treaty). If you receive a war-disablement pension that HMRC does not tax, France does not tax it either — but keep HMRC’s written confirmation that the pension is exempt, because the French inspector will ask for it. Symmetrically, certain French pensions exempt in France escape British tax whatever your nationality. These exemptions are narrow and documented, never assumed: produce the exemption, or pay the tax.
II. Paying the right French tax and challenging the wrong bill
A. Declaring every pension, claiming the allowance, and handling lump sums and QROPS transfers
French tax starts with a duty, not a choice. « En vue de l’établissement de l’impôt sur le revenu, toute personne imposable audit impôt est tenue de souscrire et de faire parvenir à l’administration une déclaration détaillée de ses revenus et bénéfices » — every taxable person must file a detailed return of income. For a British pensioner newly resident in France, that means three forms in the first spring: the main return no. 2042, where pensions go in the pensions boxes (cases 1AS and 1BS for declarants one and two); the foreign-income return no. 2047, where each British pension is listed with its country of origin so the treaty treatment and any credit can be computed; and the foreign-account return no. 3916, where you list every British bank or building-society account that received or held the money, even if the balance barely moved. File all three together, online through your personal space on impots.gouv.fr, the French tax authority’s website, and keep the filing receipts: a missing 2047 is the single most common reason the computer denies the treaty credit and taxes everything twice.
Practical evidence wins these files. Attach or keep ready for the first three years: every P60 and pension payslip, the annual statements from each scheme, proof of the exchange rate applied (the Banque de France daily rate or your bank’s actual conversion slips — pick one method and stay consistent), and, for government-service pensions, the document naming the paying public body. If you hold an S1 healthcare certificate (the form by which Britain pays France for your healthcare, typically available to State Pension recipients living in France), add a copy to the file and read our companion guide on S1 healthcare registration and refusals, because your health-cover position and your social-charges position travel together: social contributions on pension income (the CSG, contribution sociale généralisée, and CRDS, contribution au remboursement de la dette sociale) are part of what the treaty calls French tax, and — the Conseil d’État treats French social contributions as French tax covered by the treaty credit — so an S1 holder who is charged social contributions on treaty-protected income should have the credit checked line by line rather than paying in silence.
Lump sums deserve their own paragraph, because Britain and France see them through different lenses. The British 25 per cent tax-free lump sum (PCLS, pension commencement lump sum) is genuinely free of British tax, but it is not automatically free of French tax: France looks at how the rights were built up. The statute provides a dedicated home for capital payouts from foreign contracts: « Les produits attachés aux prestations de retraite versées sous forme de capital et perçues en exécution d’un contrat souscrit auprès d’une entreprise établie hors de France, lorsque le bénéficiaire justifie que les sommes versées durant la phase de constitution des droits, y compris le cas échéant par l’employeur, n’étaient pas déductibles du revenu imposable et n’étaient pas afférentes à un revenu exonéré dans l’Etat auquel était attribué le droit d’imposer celui-ci » are treated as foreign-source investment income — which, for a British scheme funded from taxed earnings, is normally satisfied, since British contributions broadly came from after-tax pay. In that configuration the lump sum joins the special investment-income treatment rather than the pensions scale, which is usually kinder. What you must never do is assume the British label settles it: gather the scheme’s contribution history, the employer’s deduction position if there was one, and the payout statement, and have the 2047 boxes completed on that evidence, not on the PCLS name. A lump sum taken the year before the move to France, while still British-resident, is a different story again — timing the crystallisation (the moment you cash in pension rights) around the move is legitimate tax planning, but it must be documented with residence dates, because the inspector will test exactly when the money became yours.
Transfers to a QROPS raise the same timing question in sharper form. Moving a British pension pot to a scheme on HMRC’s published QROPS list is not, by itself, a taxable distribution in either country: no money reaches your hands, so there is nothing for France to tax as a pension that year. Two dangers surround it. On the British side, an overseas transfer charge of 25 per cent can bite where the conditions for exclusion are not met — check the current HMRC transfer rules and the live QROPS list on the official QROPS publication before signing anything, because a transfer out of the recognised universe becomes an unauthorised payment with British charges attached. On the French side, a transfer is invisible only while it stays inside recognised pension wrappers; money that leaks out to you during the operation is a distribution like any other and follows Article 18 or the capital treatment above. Never transfer in the same spring as your first French return without aligning the paperwork: the transfer statement, the receiving scheme’s recognition reference, and the year’s 2047 must tell one consistent story, or the computer will treat the moved pot as spent income.
B. Curing double taxation and appealing an assessment before the deadline
Even with a treaty on your side, the first assessment (avis d’imposition, the printed tax bill) can be wrong: the credit missing, a government-service pension taxed as private, a lump sum pushed into the wrong boxes, social contributions charged where the treaty credit should have absorbed them. The cure has an order, and the order matters because French tax judges reason in two stages. The administrative court of appeal in Nantes restated the method for this very convention: « Si une convention bilatérale conclue en vue d’éviter les doubles impositions peut, en vertu de l’article 55 de la Constitution, conduire à écarter, sur tel ou tel point, la loi fiscale nationale, elle ne peut pas, par elle-même, directement servir de base légale à une décision relative à l’imposition. » In practice that means your challenge must first show what French domestic law does to the income — worldwide taxation under the residence rules, the pensions allowance, the scale — and only then show that the treaty displaces that result on the disputed point. A letter that waves the treaty without walking through the domestic computation reads as a slogan; a letter that walks the inspector through both stages reads as a file that will survive before a judge.
Start with the friendly stage. Write to the tax office that issued the assessment (the SIP, service des impôts des particuliers, your local personal-tax office) through your online messaging space, identifying the assessment, the pensions concerned and the treaty articles relied on, and enclosing the P60s, the British declaration evidence and the treaty print. Many missing-credit cases die at this stage, quietly corrected. If the reply is a refusal or silence, move to the formal complaint (réclamation contentieuse), which is the gateway to court: it must reach the administration « au plus tard le 31 décembre de la deuxième année suivant celle » of the collection notice, the payment where no notice was issued, or the event behind the claim — miss that New Year’s Eve and the door closes whatever the merits. The complaint states the amount, the legal grounds in both domestic law and treaty, and joins every proof in one bundle; the administration has six months to answer, and silence at six months counts as rejection and opens the two-month window to the administrative tribunal (tribunal administratif), the first-level tax court. Before the tribunal, the two-stage reasoning above becomes your skeleton: domestic computation first, treaty displacement second, evidence for each step, with the Conseil d’État credit holdings and the court of appeal method quoted in support.
Three recurring battles deserve a closing word. First, the phantom British tax: some pensioners keep paying British withholding “just to be safe” while paying full French tax, then claim nothing anywhere. Do the opposite — the treaty gives France the exclusive right under Article 18, so have Britain release the income and keep the release letter; the Conseil d’État confirms that declaring the income within a covered British tax base is enough for the French credit, since « cette condition n’exige pas que les revenus en cause aient été soumis à une imposition effective ». Second, the misclassified pension: a former public-sector worker taxed under Article 18 when Article 19 reserved the pension to Britain must separate the two treatments pension by pension, year by year, with the paying body’s identity proved — the household illustration in part I shows why the arithmetic differs. Third, the exchange-rate ambush: declare pensions converted at a consistent, defensible rate with the slips to prove it, because an inspector who cannot follow your conversion will substitute their own. In each case the file that wins is the file assembled in April, not the file reconstructed in December under a deadline: P60s, scheme statements, S1, transfer references, British declaration evidence and the treaty text, kept together from the first return onwards.
Conclusion
A British pension in France is taxed once, in the right country, if you set the machinery correctly. Residence in France hands France the pen; Article 18 reserves your State, workplace and private pensions to France with its 10 per cent allowance and household scale; Article 19 keeps former government-service pensions British unless you are French and only French; narrow war-pension exemptions remove some pensions from both; and Article 24’s credit, as the Conseil d’État reads it, mops up whatever overlap remains — even where Britain collected nothing. Declare everything on the three forms, convert consistently, keep the British evidence beside the French receipts, and challenge a wrong assessment through the complaint and the tribunal within the New Year’s Eve deadline. Pensions reward the organised: the retiree whose file already contains every proof never pays twice.