You moved to France after Brexit with a British pension behind you: a UK State Pension, a workplace pension, a personal pension, sometimes a lump sum paid out on departure and sometimes a transfer to an offshore scheme on the table. Then the letters start arriving, in two languages, from two tax administrations, and the questions pile up. Will France tax the pension that Britain already taxes? Where do you declare a pension paid into a British bank account when you live in Lyon, Bordeaux or Nice? Is the lump sum on which no UK tax was taken really safe from the French tax office? And why is there a line for social charges on income that has nothing to do with French work?<\/p>\n
This guide answers those questions in the order a British resident of France actually meets them. First, the rule that decides everything: the France-United Kingdom double tax treaty (in French, the convention fiscale<\/em>, the bilateral treaty that allocates taxing rights between the two states), which in most cases gives France, your state of residence, the exclusive right to tax your pensions. Second, the French declaration machinery: the imp\u00f4t sur le revenu<\/em> (personal income tax), the 2047 schedule for foreign-source income and the main 2042 return, with the 10 per cent allowance and the exact boxes that decide whether you pay twice or once. Third, the three traps that cost British pensioners real money: lump sums reclassified by the French courts, transfers to a QROPS (a qualifying recognised overseas pension scheme, the HMRC-supervised vehicle for moving a UK pension abroad) that trigger a 25 per cent British charge with no French deduction, and French social levies, the CSG and CRDS, applied to pensions that should have been exempt. Every decisive legal statement below is anchored to the official text it comes from, quoted word for word, with a link you can open yourself.<\/p>\n The starting point is not French domestic law and not British domestic law. It is the bilateral treaty signed in London on 19 June 2008 and published in France by the decree of 7 January 2010. For private-sector pensions, the treaty rule is simple: pensions and similar payments made to a resident of one state for work done in the past are taxable only in that state, subject only to the government-service exception described below. In plain terms, if you are resident in France and you receive a pension for your former private employment, that pension belongs to France for tax purposes, and the United Kingdom must stand back. This covers your UK State Pension, a defined-benefit workplace pension, a defined-contribution pot drawn as income, and widow’s or widower’s pensions derived from them, provided they reward former private employment rather than government service. The French administration’s commentary on the British treaty, BOI-INT-CVB-GBR-10-30, section A, on residents of France receiving private pensions of British source<\/a>, organises the practical side of this allocation, including the procedure for obtaining relief from British withholding at source.<\/p>\n Government service is the exception, and it matters to former civil servants, teachers paid by the state, National Health Service staff, police officers, members of the armed forces and local authority employees. Under the treaty’s government-service article, a pension paid by one state for public service is taxable only in that paying state. But where the pensioner is resident in the other state, holds that other state’s nationality and does not also hold the paying state’s nationality, the pension becomes taxable only in the state of residence. Dual nationals therefore stay under the first rule and the paying state keeps the taxing right. Before you declare anything, identify precisely who pays your pension and for which service, because applying the wrong half of this article is the most common source of double-taxation files on this desk.<\/p>\n The British side confirms the same logic from the opposite direction. GOV.UK explains that how much tax you pay, and where you pay it, turns on where you are treated as resident, and that a State Pension can in principle be taxed by both Britain and the country where you live. It then points to the double taxation agreement: where such an agreement exists with the country of residence, the pension is taxed once only, in whichever state the agreement designates. France has such an agreement with the United Kingdom, so the treaty allocates each pension to one state and the other must eliminate the double charge. Where both states have in fact taken tax in the meantime, GOV.UK points to the claim for tax relief that recovers some or all of the duplicate payment. Those mechanics are described on GOV.UK, tax on your State Pension if you retire abroad<\/a>. On the French side, the treaty organises that relief through a tax credit mechanism set out in its article on the elimination of double taxation, applied through your French return.<\/p>\n One practical consequence follows immediately. If HMRC continues to deduct tax at source through the British payroll system from a private pension that the treaty reserves to France, do not simply accept the deduction. Under the BOFiP procedure for residents of France receiving British-source private pensions, exemption from British withholding is granted on application, on production of a French certificate of residence, either so that the payer stops the deduction or so that tax wrongly deducted is refunded. That procedure has applied since 1 January 2012 and is set out in BOI-INT-CVB-GBR-10-30<\/a>. Keep every certificate, every refusal and every payslip: if the file later goes to litigation, the paper trail of who taxed what decides the outcome.<\/p>\n Finally, residence itself is the key that opens or closes the treaty. The treaty protects residents of France. If you split the year between Dover and Dordogne, determine your tax residence first under both domestic tests before invoking any treaty article, because everything below assumes you are fiscally domiciled in France, with your household, your main home and the centre of your economic interests there.<\/p>\n Once France has the taxing right, French domestic law takes over, and it is blunt. Article 79 of the French general tax code (the code g\u00e9n\u00e9ral des imp\u00f4ts<\/em>, France’s income tax statute)<\/a> states: “Les traitements, indemnit\u00e9s, \u00e9moluments, salaires, pensions et rentes viag\u00e8res concourent \u00e0 la formation du revenu global servant de base \u00e0 l’imp\u00f4t sur le revenu. Il en est de m\u00eame des prestations de retraite servies sous forme de capital.”<\/em> Two consequences in one paragraph. Your British pension, whatever its British label, joins your global taxable income in France. And a retirement benefit paid as a lump sum, a prestation de retraite servie sous forme de capital<\/em>, is caught by the same net. The fact that the money was earned in Britain, paid by a British scheme and left in a British bank account changes nothing once you are resident in France. As a French resident you declare your worldwide income, and the treaty decides which state taxes it, not whether it is declared.<\/p>\n The declaration itself runs through two forms that every British resident must learn by number. The impots.gouv.fr guidance on income received from abroad describes the 2047 schedule as the annexe detailing income collected abroad, expressly including pensions alongside salaries, rents, dividends and interest. You complete one 2047, pension by pension and country by country, then carry the totals onto the main 2042 return in the salary and pension boxes, and you claim the treaty relief on the supplementary 2042-C return. The administration distinguishes two relief patterns. Where the credit equals the foreign tax, you declare the gross British amount on the 2047, carry it to the 2042, and enter the credit on the dedicated lines of the 2042-C in the 8VL to 8UM range. Where the credit equals the French tax, you likewise declare the gross on the 2047 and carry it to the 2042, then report the totals on the 8TK, 4BK or 4BL lines of the 2042. These mechanics are set out in impots.gouv.fr, how income received from abroad is taxed<\/a>. These are not suggestions. A pension declared in the wrong box, or declared net of British tax instead of gross, produces a reassessment (redressement<\/em>) that is entirely avoidable. Declare the gross British amount, convert with the official annual rate, and add a note to the return identifying the treaty article you rely on.<\/p>\n The treaty credit itself was clarified for British-source income by the highest administrative court. In an opinion of 12 February 2020 on the Franco-British treaty of 19 June 2008, the Conseil d’\u00c9tat confirmed first that French social levies fall inside the treaty’s French tax net, quoting article 2: “(v) les contributions sociales g\u00e9n\u00e9ralis\u00e9es […] (vi) les contributions pour le remboursement de la dette sociale”<\/em> That is Conseil d’\u00c9tat, opinion of 12 February 2020, No. 435907, ECLI:FR:CECHR:2020:435907.20200212<\/a>, paragraph 1. The court then held that France may not refuse the treaty credit against French social contributions merely because no equivalent income tax exists in the United Kingdom, and, decisively for pensioners whose British income bears little or no British tax, that the credit condition does not require taxation actually paid: “cette condition n’exige pas que les revenus en cause aient \u00e9t\u00e9 soumis \u00e0 une imposition effective”<\/em> (paragraph 6). It is enough that the income was declared in Britain within the base of a covered British tax, even where no British tax was ultimately paid: “la condition pr\u00e9vue \u00e0 l’alin\u00e9a (i) du a) du paragraphe 3 de l’article 24 de la convention doit \u00eatre regard\u00e9e comme satisfaite s’il est \u00e9tabli par le r\u00e9sident de France qu’il a d\u00e9clar\u00e9 les revenus en cause au Royaume-Uni, parce que ces revenus \u00e9taient compris dans la base de l’un des imp\u00f4ts \u00e9num\u00e9r\u00e9s au a) du 1 de l’article 2 de la convention, alors m\u00eame qu’il n’aurait acquitt\u00e9 dans cet Etat aucun imp\u00f4t \u00e0 raison de ces revenus”<\/em> (paragraph 7). For a British pensioner in France, the message is concrete: declare the pension in both countries, keep the British return as proof, and claim the French credit even where Britain took nothing.<\/p>\n On the amount itself, French law grants pensioners an automatic allowance that many British residents overlook. Article 158, 5, a of the general tax code<\/a> provides: “Les pensions et retraites font l’objet d’un abattement de 10 % qui ne peut exc\u00e9der 4 439 \u20ac.”<\/em> The same paragraph adds the floor: “L’abattement indiqu\u00e9 au deuxi\u00e8me alin\u00e9a ne peut \u00eatre inf\u00e9rieur \u00e0 454 \u20ac, sans pouvoir exc\u00e9der le montant brut des pensions et retraites.”<\/em> In practice, the tax office deducts 10 per cent from your declared pensions before applying the progressive scale, within that ceiling and that floor per pensioner in the household (the foyer fiscal<\/em>, the French tax household of spouses, partners and dependent children taxed jointly). Check the figures on your assessment notice (avis d’imposition<\/em>): the allowance is applied by the administration, but on a mis-coded return it is sometimes missed, and the correction is then a simple claim.<\/p>\n One more box deserves attention, because it links your tax return to your healthcare cover. The impots.gouv.fr guidance on foreign income explains that taxpayers covered by the health system of a European Economic Area state or Switzerland, who are not dependent on a compulsory French scheme, tick boxes 8SH for the first declarant and 8SI for the second, in section 8 (Miscellaneous) of the supplementary 2042-C return. Those boxes tell the administration that you depend on a foreign health scheme rather than a compulsory French one, which is exactly the position of a British pensioner registered in France with an S1 healthcare certificate (the portable document by which the United Kingdom remains responsible for your healthcare costs while you live in France). Since the United Kingdom left the European Union, coordination continues under the Withdrawal Agreement, but the wording of the boxes follows the current year’s 2042-C notice, so verify that notice before ticking. The details are in the same impots.gouv.fr guidance<\/a>. The box you tick in May decides the social-charge bill you receive in autumn, as the second part of this guide explains.<\/p>\n The most expensive misunderstanding on this desk is the belief that a lump sum untouched by British tax is untouched by French tax. Article 79, quoted above, says the opposite: retirement benefits paid as capital join global income. French law then offers a genuine planning tool, but fenced with conditions that the courts enforce strictly. The Bordeaux administrative court of appeal restated the mechanism in a December 2025 judgment concerning a foreign employer pension paid as a lump sum of 411,091 euros: “le l\u00e9gislateur a entendu ouvrir aux contribuables personnes physiques titulaires de prestations de retraite vers\u00e9es sous forme de capital qui y trouvent avantage la facult\u00e9 d’opter, en lieu et place d’une taxation au bar\u00e8me progressif de l’imp\u00f4t sur le revenu, pour l’application aux sommes en cause d’un pr\u00e9l\u00e8vement forfaitaire de 7,5 % lib\u00e9ratoire de l’imp\u00f4t sur le revenu.”<\/em> That is CAA Bordeaux, 6th chamber, 3 December 2025, No. 23BX02970<\/a>, paragraph 4. Instead of the progressive scale, you may elect, expressly and irrevocably, a flat 7.5 per cent levy that discharges income tax, computed after a 10 per cent reduction. The statutory conditions, recalled at paragraph 3 of the same Bordeaux judgment No. 23BX02970<\/a>, are: “Les prestations de retraite vers\u00e9es sous forme de capital imposables conform\u00e9ment au b quinquies du 5 de l’article 158 peuvent, sur demande expresse et irr\u00e9vocable du b\u00e9n\u00e9ficiaire, \u00eatre soumises \u00e0 un pr\u00e9l\u00e8vement au taux de 7,5 % qui lib\u00e8re les revenus auxquels il s’applique de l’imp\u00f4t sur le revenu.”<\/em> And: “Ce pr\u00e9l\u00e8vement est applicable lorsque le versement n’est pas fractionn\u00e9 et que le b\u00e9n\u00e9ficiaire justifie que les cotisations vers\u00e9es durant la phase de constitution des droits, y compris le cas \u00e9ch\u00e9ant par l’employeur, \u00e9taient d\u00e9ductibles de son revenu imposable ou \u00e9taient aff\u00e9rentes \u00e0 un revenu exon\u00e9r\u00e9 dans l’Etat auquel \u00e9tait attribu\u00e9 le droit d’imposer celui-ci”<\/em> One payment in one go, and proof about the contributions paid while the rights were being built up. Miss either limb and the option collapses.<\/p>\n The Bordeaux case shows what happens when the nature of the payment itself is wrong. The taxpayers had received 411,091 euros from an international employer’s savings arrangement and claimed the 7.5 per cent treatment. The court examined the two schemes side by side and held that the disputed sum “ne pr\u00e9sente pas le caract\u00e8re d’une pension de retraite vers\u00e9e en capital mais rel\u00e8ve de la cat\u00e9gorie des revenus de capitaux mobiliers”<\/em> (CAA Bordeaux No. 23BX02970<\/a>, paragraph 7): not a retirement pension paid as capital, but investment income. The administration was therefore allowed to change the legal basis of the assessment onto article 120, 6\u00b0 of the general tax code<\/a>, as characterised in the same Bordeaux judgment<\/a>: “Sont consid\u00e9r\u00e9s comme revenus au sens du pr\u00e9sent article : (…) 6\u00b0 Les int\u00e9r\u00eats, arr\u00e9rages et tous autres produits des obligations des soci\u00e9t\u00e9s, compagnies et entreprises d\u00e9sign\u00e9es aux 1\u00b0 et 2\u00b0, et notamment les produits attach\u00e9s aux bons ou contrats de capitalisation ainsi qu’aux placements de m\u00eame nature souscrits aupr\u00e8s d’entreprises d’assurance \u00e9tablies hors de France, lors du d\u00e9nouement du contrat, et les gains de cessions de ces m\u00eames placements (…)”<\/em> The outcome is instructive in both directions. The taxpayers lost the pension treatment, but they won a substantial reduction: because the payment mixed employer contributions and fund growth, only the growth portion could be taxed as investment income, and the court cut the uplift from 411,091 euros of salary-type income to 257,135 euros of foreign investment income, discharging the surplus: “M. et Mme C… sont d\u00e9charg\u00e9s, en droits et majorations, des cotisations suppl\u00e9mentaires d’imp\u00f4t sur le revenu auxquelles ils ont \u00e9t\u00e9 assujettis au titre de l’ann\u00e9e 2015 formant surtaxe par rapport \u00e0 celles r\u00e9sultant de l’application de l’article 1er du pr\u00e9sent arr\u00eat.”<\/em> Three lessons for British readers. First, label nothing yourself: a British commencement payment may be a French pension paid as capital, or it may be French investment income, and the scheme documents decide. Second, keep the contribution history, because deductibility during the build-up phase is the gateway to the 7.5 per cent levy. Third, even a lost characterisation can be mitigated by taxing only the gain, not the whole capital, which is why the file must separate contributions from growth from the start.<\/p>\n The second trap is the transfer itself. Moving a UK pension to a QROPS, typically established in Malta or Gibraltar since France hosts practically none, is a British taxable event before it is a French one. HMRC’s official guidance sets the overseas transfer charge at one quarter of the transferred value, a figure that can erase a large part of the fund on the day of the move. The full calculation rules are in GOV.UK, the overseas transfer charge guidance<\/a>. Exclusions exist, and they are narrow: no charge where the member is tax-resident in the same country where the receiving QROPS is established, or where both the member’s residence and the QROPS sit inside the European Economic Area. A British resident of France transferring to a QROPS established in the EEA may therefore escape the charge, but the residence test is applied strictly, the information duties are heavy, and a later change of residence within five years can revive the charge retrospectively. France, for its part, grants no deduction for a British transfer charge: it is not French tax, it generates no French credit, and it does not reduce the taxable pension. Before signing any transfer, check the current HMRC-published QROPS list yourself, take the five-year residence picture in writing, and compare the certain British cost against the uncertain French benefit. A transfer driven by a salesman without that comparison is how files end with a charge in London and a reassessment in Paris.<\/p>\n Income tax is only half the bill. France adds social levies, the CSG (the contribution sociale g\u00e9n\u00e9ralis\u00e9e<\/em>, the general social contribution) and the CRDS (the contribution au remboursement de la dette sociale<\/em>, the social debt repayment contribution), and British pensioners are regularly charged them when they should not be, or at the wrong rate when they should. The rate depends on your revenu fiscal de r\u00e9f\u00e9rence<\/em> (your reference tax income, the benchmark figure printed on your assessment notice) and your household shares. The ministry of the economy publishes the current scale, which runs from full exemption through reduced and middle rates to the standard rate, with only part of the CSG deductible against income tax and the CRDS charged at a single flat rate in every band. The current figures and the deductible slices are in the economie.gouv.fr guide to CSG and CRDS rates on retirement pensions<\/a>, confirmed by service-public.fr, CSG and CRDS on activity and replacement income<\/a>, which recalls that the two levies apply to replacement income including retirement pensions, that rates vary with the situation and that some income is exempt. The legal base sits in the social security code, whose article L. 136-6<\/a> defines the scope of the contribution. Two checks, then, on every bill: the rate against your reference tax income, and the very principle of liability.<\/p>\n The principle is where British S1 holders win. European coordination rests on a single rule: one person, one social security legislation at a time. The Court of Cassation restated it in September 2025: the coordination regulations “consacrent le principe d’unicit\u00e9 de la l\u00e9gislation de s\u00e9curit\u00e9 sociale, selon lequel la personne \u00e0 laquelle les r\u00e8glements s’appliquent n’est soumise qu’\u00e0 la l\u00e9gislation d’un seul \u00c9tat membre, en sorte que celle-ci, affili\u00e9e \u00e0 un r\u00e9gime de s\u00e9curit\u00e9 sociale d’un \u00c9tat membre, ne doit pas contribuer au r\u00e9gime de s\u00e9curit\u00e9 sociale d’un autre \u00c9tat membre (CJUE, arr\u00eat du 26 f\u00e9vrier 2015, De Ruyter, C-623-13, point 35).”<\/em> That is Court of Cassation, 2nd civil chamber, 25 September 2025, No. 22-24.634, ECLI:FR:CCASS:2025:C200872<\/a>, paragraph 4. The same judgment recalls the practical consequence for persons attached to the French health system by residence but covered elsewhere: “Ils ne sont pas assujettis aux contributions vis\u00e9es \u00e0 l’article L. 136-1 et \u00e0 l’article 14 de l’ordonnance n\u00b0 96-50 du 24 janvier 1996 relative au remboursement de la dette sociale et ne sont pas redevables des cotisations vis\u00e9es \u00e0 l’article L. 131-9 et \u00e0 l’article L. 380-2.”<\/em> (paragraph 10). Translate that to your situation: a British pensioner whose healthcare is carried by the United Kingdom under an S1, registered with the local health fund (the CPAM, the caisse primaire d’assurance maladie<\/em>, your local health insurance office) but financially the responsibility of Britain, is not financing the French health system twice. CSG and CRDS demanded on the pension in that configuration must be contested. The appeal in the 2025 case was ultimately rejected on its own facts, concerning cross-border workers who had opted into the French scheme, which is precisely why your file must prove the opposite configuration: S1 registered, British cover, no French health financing. This is also why the 8SH and 8SI boxes on the 2042-C, discussed above, matter so much: they are the administration’s own marker of that configuration.<\/p>\n When the bill is wrong, the procedure is fixed and the deadlines are short. First, file a formal claim (r\u00e9clamation<\/em>) with the tax office that issued the notice, identifying the treaty article or the coordination rule, attaching the S1, the residence certificate, the British deduction slips and the assessment. Second, if the claim is rejected expressly or by silence, appeal to the administrative court (tribunal administratif<\/em>) within two months of the rejection, then to the administrative court of appeal (cour administrative d’appel<\/em>) as in the Bordeaux judgment above. Against a health fund’s position, the route runs through the fund’s own review and then the social courts. Administrative comments published in the BOFiP can be invoked against the administration where they add to the statute, but as Bordeaux recalled, comments that merely restate the law change nothing, so plead the treaty and the code first and the commentary second. Never let a notice become final while you gather documents from Britain: file the claim first to stop the clock, then complete the evidence.<\/p>\n A British pension in France is taxed once, in the right state, if you force the machinery to work as written. Identify your treaty rule: residence-state taxation for private pensions, paying-state taxation for most government-service pensions, with the nationality exception that returns some pensions to France. Declare worldwide income through the 2047 schedule carried onto the 2042, claim the 10 per cent allowance, and use the treaty credit, which the Conseil d’\u00c9tat confirms needs no British tax actually paid, so that a British deduction at source becomes a refund rather than a double charge. Treat every lump sum as taxable in France until proven otherwise, test the 7.5 per cent flat levy against its two statutory conditions, and never move a pot to a QROPS without pricing the 25 per cent British charge against a written five-year residence picture. Verify the CSG and CRDS rate against your reference tax income, and where an S1 puts your healthcare on Britain, contest the levies with the coordination case law rather than paying them. The documents decide these files: scheme rules, contribution histories, S1 certificates, residence proofs and every assessment notice, kept together from the first year. Assembled early, they make a routine return; assembled late, they make litigation.<\/p>\n If your British pension is taxed in both countries, if a lump sum or a QROPS transfer has drawn a reassessment, or if CSG and CRDS appear on income covered by your S1, send the notices and the pension documents for review. Telephone consultation: 80 EUR including VAT, with an avocat of the firm within 48 hours. Call +33 6 46 60 58 22<\/a> or write via the contact page<\/a>.<\/p>\n","protected":false},"excerpt":{"rendered":" British resident in France? Your UK State and private pensions are usually taxable only in France under the 2008 treaty. Declaration via forms 2047 and 2042, lump sums, QROPS 25% charge, CSG-CRDS and how to challenge a wrong bill.<\/p>\n","protected":false},"author":251031309,"featured_media":16403,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_kj_source_type":"","_kj_official_id":"","_kj_official_url":"","_kj_judilibre_id":"","_kj_jur":"","_kj_lieu":"","_kj_chambre":"","_kj_rg":"","_kj_date":"","activitypub_content_warning":"","activitypub_content_visibility":"","activitypub_max_image_attachments":4,"activitypub_interaction_policy_quote":"anyone","activitypub_status":"federated","footnotes":""},"categories":[80312,80314],"tags":[],"class_list":["post-2128565","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-british-desk","category-decryptage"],"yoast_head":"\nI. Is my UK pension taxed in France or in the United Kingdom now that I live in France?<\/h2>\n
A. Which country taxes my State Pension and my private pension under the France-United Kingdom tax treaty?<\/h3>\n
B. How do I declare my UK pension in France: forms 2047, 2042 and the 10 per cent allowance?<\/h3>\n
II. Lump sums, QROPS transfers and social charges: what else can hit my British pension in France?<\/h2>\n
A. Is my pension lump sum taxable in France, and should I move my pot to a QROPS?<\/h3>\n
B. Do I pay French social charges on my UK pension, and how do I challenge a wrong bill?<\/h3>\n
Conclusion<\/h2>\n
Need a quick opinion on your case<\/h2>\n