With early and careful planning, you can make the most of tax-efficient opportunities when moving to France or buying a French property.
Thinking of moving to France or buying a property across the Channel? While foreign bureaucracy and tax legislation may seem off-putting, with early and careful planning, you can prevent headaches and make the most of tax-efficient opportunities. Here are eight key considerations.
1. Where you will pay tax
You need to establish exactly when you become liable for French tax on your worldwide income, gains, wealth and estate.
Generally, once you arrive in France intending to live there permanently, you become French tax resident the following day. But it is not always so straightforward. You could be considered resident even if you do not live in France but your spouse does, or if your main home is in France.
You also need to be wary of UK tax residence rules – you could, for example, unintentionally trigger UK tax residency by spending just 16 days back home.
If you plan carefully and have some flexibility, it is possible to time your residency switch to minimise your tax liabilities in both countries.
2. How you will be taxed
French taxation can be complicated… and high. Besides income tax peaking at 45%, you also face up to 15.5% ‘social charges’ on most income. Currently, an annual wealth tax also applies if your household’s taxable assets exceed €1.3 million.
But with expert tax planning, it is possible to structure savings, investments and assetsto be tax-efficient – and maybe even pay less tax in France than you did in the UK, depending on your circumstances.
Once resident in France, you are responsible for making yourself known to the French tax authorities and declaring your worldwide income, capital gains and wealth. Taxes are declared a year in arrears, so your first tax return is usually due around the end of May the year after arrival.
Unlike the UK, French tax rates are not calculated by individual income, but by dividing the total income of a household by the number of family members. This can result in lower taxation in households with high income but several ‘parts familiales’. See more about French taxes
3. Ways to structure your wealth
Do not assume that what is tax-efficient at home will be the same in France. ISAs, for example, lose their tax-free status once you are no longer UK resident, and interest attracts both French income tax and social charges.
Your circumstances and goals will almost certainly change when you relocate too. It is crucial to take a fresh look at your financial planning to make sure your affairs are set up in the best way for your new life in France.
If you have investment capital, take professional advice to establish the most tax-efficient structures for French residents. An adviser with cross-border expertise can recommend suitable investment vehicles that provide considerable tax advantages to suit you and your particular circumstances as an expatriate.
4. Which currency works for you
Although Britons living in France tend to favour sterling for savings and investments, this makes income vulnerable to exchange rate fluctuations, which can impact returns. Ideally you should hold some assets in euros to avoid exchange rate risk, especially during this time of Brexit volatility.
However, you may also want to spend money in the UK, return someday or leave an inheritance to UK residents. Ask your adviser about investment structures that let you diversify by holding multiple currencies or consider transferring UK pensions to arrangements offering currency flexibility.
5. Your property options
Understanding the tax implications before buying and selling property could save thousands. Are you better off selling UK property now or should you wait until you are living in France? Rules, rates and allowances differ in each country, so take advice to establish what works best for you.
If you are looking to buy a French home, note that there are various ways of owning property, each with different tax implications. For example, several people – including children – can share ownership using a French property holding company called an SCI (Société Civile Immobilière). Alternatively, you could reduce succession tax by giving ownership to heirs while keeping the right to live in the property through an ‘usufruit’.
The most suitable option for you will depend on your family situation, what you want to happen to the property on death and how you will use it – will you live there full-time, treat it as a holiday home or rent it out? Advice is essential to understand your best approach.
6. What to do with UK pensions
When living abroad, many Britons find it beneficial to transfer UK pension funds into a Qualifying Recognised Overseas Pension Scheme (QROPS) to enjoy tax efficiency, flexibility and estate planning advantages over UK pensions.
Alternatively, you could potentially take out your UK pension fund as a lump sum and pay just 7.5% tax in France under certain circumstances. You could then re-invest the capital into tax-efficient arrangements in France to make your retirement savings go further. See more about your pension options
However, there is no ‘one size fits all’ solution. With something as important as your pension, it is vital to take regulated professional advice tailored for you and your particular situation before making decisions.
7. How your legacy will be passed on
In France, succession law and inheritance taxes work very differently from the UK and are particularly complicated. Getting it wrong can have serious consequences for your heirs, especially if you have children from previous relationships or want to leave assets to distant or non-relatives. These beneficiaries can face succession taxes as high as 60%.
Beware also the ‘forced heirship’ rules in French succession law. This can automatically pass on up to 75% of your estate to your children, regardless of your intentions. There are ways to nominate UK inheritance law instead, but take care to understand all the pros and cons first. See more about estate planning
8. Planning for Brexit
While there is still uncertainty around what Brexit will mean in practice, the rights of Britons living in France cannot change before March 2019 when Britain leaves the EU.
New reciprocal agreements are likely to protect existing residents, so if you are serious about living in France, consider moving and securing your residency sooner rather than later. It may also be a good idea to act now, under known rules, if you are thinking about buying property in France or moving your pensions out of the UK, rather than waiting to see what changes post-Brexit.
Ultimately, you need professional advice to make the most of tax planning, pension and wealth management opportunities in France, and ensure you use legitimate arrangements that suit your specific circumstances.
UK financial advisers, however, are unlikely to be up-to-date with the intricacies of French taxation and the frequent changes to the tax regime. Speak to an adviser based in France who has specific cross-border experience with British expatriates. With proper guidance, you can have peace of mind that your financial affairs are in order so you can relax and fully enjoy your new life in France.
Find out more about living in France
Tax rates, scope and reliefs may change. Any statements concerning taxation are based upon our understanding of current taxation laws and practices which are subject to change. Tax information has been summarised; an individual is advised to seek personalised advice.