You moved to France after Brexit, kept your London job, and work from your house in the Dordogne or Normandy. Every month a neat British payslip arrives, income tax and National Insurance disappear through PAYE (Pay As You Earn, the British system under which the employer deducts tax and social charges from wages before paying them), and life feels settled. Then a letter arrives from URSSAF (Unions de recouvrement des cotisations de s\u00e9curit\u00e9 sociale et d’allocations familiales, the French bodies that collect social security contributions), or your employer suddenly asks whether it should be running a French payroll. The demand can cover several years of contributions, and the language is uncompromising.<\/p>\n
This situation traps thousands of Britons. The misunderstanding is natural: if the employer is British, the contract is English, and HM Revenue and Customs already takes its share, surely nothing is owed in France. French law answers the opposite. Social security follows the place where the work is actually done, not the address on the employer’s letterhead, and income tax follows the person who lives and works in France. A British payroll neither exempts the salary from French charges nor settles the French tax bill. This article explains why France claims your salary from day one, how an URSSAF reassessment (redressement, the formal correction of unpaid contributions) is constructed, and the practical routes to challenge the bill or regularise your position.<\/p>\n
French social security works on a territorial principle: the legislation of the place of work applies. The cornerstone sits in the Social Security Code. Article L. 311-2 provides that “Sont affili\u00e9es obligatoirement aux assurances sociales du r\u00e9gime g\u00e9n\u00e9ral, quel que soit leur \u00e2ge et m\u00eame si elles sont titulaires d’une pension, toutes les personnes quelle que soit leur nationalit\u00e9, de l’un ou de l’autre sexe, salari\u00e9es ou travaillant \u00e0 quelque titre ou en quelque lieu que ce soit, pour un ou plusieurs employeurs et quels que soient le montant et la nature de leur r\u00e9mun\u00e9ration, la forme, la nature ou la validit\u00e9 de leur contrat ou la nature de leur statut.”<\/a> Read that sentence twice. Nationality is irrelevant. The nature, form and even validity of the contract are irrelevant. What counts is salaried work performed on French soil. A Briton typing for a London company from a desk in Bergerac is caught exactly as if the employer sat across the street.<\/p>\n Remote work changes nothing, and the Code says so almost expressly. Article L. 311-3 extends the same compulsory affiliation to listed categories of workers “m\u00eame s’ils ne sont pas occup\u00e9s dans l’\u00e9tablissement de l’employeur ou du chef d’entreprise”<\/a>, even where they are not employed on the employer’s premises. Working from home, from a spare room or from a rented office in France is employment outside the employer’s establishment by definition. The fact that the establishment happens to be in Shoreditch rather than Saint-Denis makes the case stronger, not weaker.<\/p>\n URSSAF itself publishes this reading for foreign employers. Its foreign-firms service<\/a> states the rule plainly: where a company has no French establishment and engages an employee covered by the French social security scheme, it must declare and pay the social contributions in France. The same page lists the situations covered, starting with the employee who works permanently on French territory and therefore belongs to the French scheme<\/a>. A Briton who has relocated to France and works from home full time is the textbook example. A second listed case matters for shorter stays: an employee sent temporarily to France who does not benefit from a posting arrangement keeping them under the foreign scheme falls under the French scheme<\/a> as well.<\/p>\n That second case introduces the only real escape route, called d\u00e9tachement in French and posting or detached-worker status in English: a temporary secondment during which the worker remains covered by the home State’s scheme. Since 1 January 2021 this bridge is governed for Britons by the social security Protocol to the EU-UK Trade and Cooperation Agreement, alongside the Withdrawal Agreement for those already mobile before that date. The French liaison body Cleiss (Centre des liaisons europ\u00e9ennes et internationales de s\u00e9curit\u00e9 sociale, the official Franco-international social security liaison centre) explains that the Trade and Cooperation Agreement in force since 1 January 2021 allows postings to France capped at 24 months<\/a>. Such a posting needs an A1 portable document, the European certificate proving which State’s legislation applies, requested before the assignment with prior notification. The logic is strict: posting covers a temporary assignment with a foreseeable end, decided by the employer, after which the worker returns. A permanent move to France to work remotely for the same London employer, with no return date and a French home as the centre of life, is not a posting in any serious sense. Claiming A1 cover for it invites URSSAF to reclassify the whole period and bill the contributions with penalties.<\/p>\n A mixed pattern needs a formal determination rather than guesswork. Many Britons work mainly from France with regular days in the London office. European coordination rules then assign the worker to one single State’s scheme, never two at once, determined by the criteria laid down in the coordination regulations<\/a>. For someone resident in France and working substantially there, that single State is normally France, with the local health fund (CPAM, Caisse primaire d’assurance maladie) as the point of contact. The practical lesson is uncomfortable but simple. If you live in France and your hands are on the keyboard in France, the default answer is the French scheme, full French employer and employee contributions, and a registration duty on the British employer. British PAYE deductions and National Insurance payments change nothing about that default; at most they create double payments to be sorted out, never an exemption.<\/p>\n The tax analysis runs on parallel rails and reaches the same station. France taxes its residents on worldwide income, and a Briton living and working full time in France is normally a French tax resident under domestic law. Article 4 B of the General Tax Code treats as fiscally domiciled in France “1. Sont consid\u00e9r\u00e9es 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 s\u00e9jour principal ; b. Celles qui exercent en France une activit\u00e9 professionnelle, salari\u00e9e ou non, \u00e0 moins qu’elles ne justifient que cette activit\u00e9 y est exerc\u00e9e \u00e0 titre accessoire”<\/a>. A permanent home in France, or a salaried activity exercised in France otherwise than incidentally, each suffices. The remote worker from the introduction meets both tests at once, which means the salary must be declared in France even though it is paid from London and even though PAYE has already bitten in Britain.<\/p>\n Where both States claim the same person, the France-United Kingdom double tax convention signed on 19 June 2008 provides the tie-breaker. Its Article 4 provides that a person resident in both States is deemed resident only of the State where they have a permanent home, or, with homes in both States, of the State with which personal and economic relations are closer, the centre of vital interests<\/a>. For a Briton whose family home, daily life and actual work are all in France, with only the employer’s office and perhaps a rented flat in London remaining, that centre of vital interests test points to France in most cases. The remaining tie-breaker stages, habitual abode then nationality then mutual agreement between the authorities, only matter in genuinely balanced cases.<\/p>\n Residence decided, the convention allocates the salary itself. Article 15 on income from employment lays down the workplace rule: employment income is taxable only in the worker’s State of residence unless the employment is exercised in the other State, in which case that other State may tax the corresponding remuneration<\/a>. Work exercised in France may therefore be taxed in France. The well-known 183-day exception does not save the permanent remote worker, because all three of its conditions must be met together: presence in the State of work not exceeding 183 days in any twelve-month period, payment by an employer not resident there, and remuneration not borne by a local permanent establishment<\/a>. Someone present and working in France year-round fails the first condition immediately. Double taxation is then relieved mechanically, through the convention’s elimination article and foreign tax credit claims, but relief is not exemption: France taxes first in principle, and Britain gives credit. Concretely, declare the full gross salary on the French return, claim credit for the British tax attributable to it, and keep every P60 (the British annual certificate of pay and tax deducted) and payslip. The dangerous belief that PAYE discharge ends the story produces the classic double failure: undeclared French income plus unpaid French social charges, discovered together during the same audit.<\/p>\n An URSSAF file almost always starts the same way: a control, then a formal observations letter (lettre d’observations) listing each ground of reassessment, then a registered formal demand (mise en demeure) stating the sums, and finally an enforceable collection order (contrainte) if payment or challenge does not follow. Understanding each layer matters because each carries its own challenge route, and silence converts a contestable claim into an enforceable debt. The employer’s first duty, often the first breach, is the hiring declaration. Article L. 1221-10 of the Labour Code states that “L’embauche d’un salari\u00e9 ne peut intervenir qu’apr\u00e8s d\u00e9claration nominative accomplie par l’employeur aupr\u00e8s des organismes de protection sociale d\u00e9sign\u00e9s \u00e0 cet effet.”<\/a> No hiring without a prior nominative declaration (DPAE, d\u00e9claration pr\u00e9alable \u00e0 l’embauche) to the designated social protection bodies, in every place of work where employees are engaged. A London company that starts a remote worker in France without any French declaration breaches this duty from the first day of work, however properly the worker is registered for PAYE in Britain.<\/p>\n Deliberate non-declaration escalates the file from a civil debt into concealed-work territory (travail dissimul\u00e9, the French offence of hiding an activity or an employee from the authorities). The Court of Cassation regularly recalls the statutory definition, recalling that “est r\u00e9put\u00e9 travail dissimul\u00e9 par dissimulation d’emploi salari\u00e9 le fait pour tout employeur : 1\u00b0 Soit de se soustraire intentionnellement \u00e0 l’accomplissement de la formalit\u00e9 pr\u00e9vue \u00e0 l’article L. 1221-10 du code du travail, relatif \u00e0 la d\u00e9claration pr\u00e9alable \u00e0 l’embauche”<\/a>, alongside deliberate failure to issue payslips (bulletins de paie) or to declare wages and contributions to the collection bodies, as set out in article L. 8221-5 of the Labour Code<\/a>. That decision, given by the Second Civil Chamber on 16 October 2025 in case 23-14.039 concerning a Portuguese company controlled in France, shows how inspectors use these texts against foreign employers: no French declaration, no contributions, no posting certificates produced, and the reassessment follows. The criminal courts apply the same logic to directors. On 2 March 2021 the Criminal Chamber maintained concealed-work convictions where a foreign company operated through a permanent representation at its director’s French home without French registration, the appeal judges having held that “l’employeur est assujetti aux dispositions du code du travail applicables aux entreprises \u00e9tablies sur le territoire national”<\/a>, with all the criminal provisions of the judgment expressly maintained. A British employer directing French-based staff from a laptop in Lyon should read that warning carefully: directing activity on French soil without French registration is precisely the pattern the courts punish.<\/p>\n The money itself is then calculated on the salary. Article L. 242-1 of the Social Security Code provides that “Les cotisations de s\u00e9curit\u00e9 sociale dues au titre de l’affiliation au r\u00e9gime g\u00e9n\u00e9ral des personnes mentionn\u00e9es aux articles L. 311-2 et L. 311-3 sont assises sur les revenus d’activit\u00e9 tels qu’ils sont pris en compte pour la d\u00e9termination de l’assiette d\u00e9finie \u00e0 l’article L. 136-1-1 .”<\/a> Contributions for persons covered by Articles L. 311-2 and L. 311-3 sit on activity income, which in practice means the gross salary including most bonuses and benefits in kind, with both an employer share and an employee share. Over several years of undeclared remote work the principal alone is heavy, and it arrives with late-payment surcharges. Procedurally, the formal demand must be precise and reasoned: the Code requires that where recovery does not come through the public prosecutor, the warning is replaced by “une mise en demeure adress\u00e9e par lettre recommand\u00e9e ou par tout moyen donnant date certaine \u00e0 sa r\u00e9ception par l’employeur ou le travailleur ind\u00e9pendant”<\/a>, a demand sent by registered letter or any means giving a certain date of receipt. That sentence is your shield as much as their sword. An imprecise or unmotivated demand, a notification sent to the wrong address, or a demand that lumps together periods and legal bases without detail can all be attacked before the friendly-appeal commission (commission de recours amiable, the internal URSSAF appeal body that must be seized before going to court) and then before the judicial court, exactly the path traced in the reported cases where employers challenged observations letters and demands all the way to the Court of Cassation.<\/p>\n Regularisation starts with registration, and URSSAF designates a single door for it. The foreign-firms service (SFE, service firmes \u00e9trang\u00e8res) acts as the single entry point for the employer’s French formalities and for declaring and paying contributions<\/a>. Registration itself runs through the business formalities portal, since the employer must complete its creation declaration on the INPI single window (guichet unique, the French central portal for business registration formalities). Once registered, the employer files the prior hiring declaration, issues French-compliant payslips, and declares and pays everything each month. For the past, spontaneous regularisation before any control generally produces a far lighter outcome than the same corrective payments after inspectors arrive with a concealed-work file. Quantifying the arrears early, provisioning them, and presenting a registration timetable through professional advice often converts a criminal-risk file back into a payment-schedule discussion.<\/p>\n Three common mistakes must be avoided during that process. First, manufacturing a posting after the fact. An A1 certificate genuinely covers a temporary assignment decided in advance with prior notification, and inspectors verify the paper trail; requesting one to dress up years of permanent remote work as a secondment destroys credibility and can aggravate the file. Second, splitting presence artificially. Spending two days a week in the London office does not make the other three French days disappear; multi-State workers belong to one single scheme determined by residence and substantial activity, and for a French resident working mostly from France that determination will normally confirm France through the local health fund. Third, ignoring the British side while fixing the French side. Years without British National Insurance can dent the future UK State Pension record, and the British guidance confirms that voluntary National Insurance contributions while working abroad are possible in some cases<\/a>. Checking that option with HM Revenue and Customs while the French registration is put in order protects both retirement records at once.<\/p>\n Challenging a demand already received follows a different discipline. Read the observations letter line by line and match every ground to evidence: employment contracts showing the real place of work, travel records proving presence, any A1 or determination decision, payslips on both sides of the Channel, and proof of which contributions were actually paid where. Attack imprecision first, since the demand must be precise and reasoned; then attack the legal characterisation, since genuine postings with valid A1 documents and properly determined multi-State situations fall outside the French scheme; and only then discuss figures, since the contribution base excludes certain sums by statute. File the friendly-appeal challenge within the stated time limit on the demand itself, never letting the collection order become final by default, and keep paying what is indisputably due where payment suspends enforcement. Above all, do not improvise statements to inspectors about where work was performed: those minutes become the backbone of the file. Diaries, badge records, train and flight bookings, and the employer’s own assignment emails often decide the case well before any legal argument is heard, so assemble them early and keep every version consistent across tax and social security filings. A short, documented, professionally framed response directly beats a long explanatory letter every time, and where the demand mixes sound and unsound grounds, partial challenge preserves credibility for the points that truly deserve to fall.<\/p>\n Living in France while remaining on a British payroll feels administratively invisible, which is exactly why it is dangerous. French social security claims the salary because the work is done in France, whatever the employer’s nationality and whatever PAYE has deducted. French income tax claims the same salary because the worker’s home and professional activity are in France, with the 2008 convention allocating the taxing right to France and offering credit rather than exemption. The British employer must register with the French system and pay French contributions, and failure to do so builds a file that runs from the observations letter through the formal demand to the enforceable order, with concealed-work exposure at the far end. The way out is methodical: determine the applicable legislation honestly, register through the proper French service, protect the British contribution record voluntarily where useful, and challenge any demand precisely and on time. Handled early with proper registration, this is an administrative exercise. Done after the inspectors arrive, it is litigation. The difference between the two is measured in years of arrears, and it starts the day the remote worker unpacks in France.<\/p>\n Discuss your situation in a telephone consultation within 48 hours with an avocat of the firm. Initial telephone consultation: 80 EUR incl. VAT. Call +33 6 46 60 58 22<\/a> (Ma\u00eetre Reda Kohen), or write to us through our contact page<\/a>.<\/p>\n","protected":false},"excerpt":{"rendered":" Living in France but still paid through a UK payroll? France claims French social charges and income tax from day one. How URSSAF builds the bill, and how to challenge or regularise it.<\/p>\n","protected":false},"author":251031309,"featured_media":16421,"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-2131110","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-british-desk","category-decryptage"],"yoast_head":"\nB. Income tax follows the person who lives and works in France<\/h3>\n
II. URSSAF sends a reassessment: read the bill, then answer it<\/h2>\n
A. How the bill is built and why it hurts<\/h3>\n
B. Regularise the position and challenge the demand without making it worse<\/h3>\n
Conclusion<\/h2>\n
Need a quick opinion on your case.<\/h2>\n