Living in France, Working in the UK
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Living in France, Working in the UK
Hi,
Firstly sorry if this is in the wrong place/already discussed, I did a search but couldn't find anything.
I'm currently working in the UK and looking to move to France and commute, for various personal reasons. And I ideally want to get this done before the big Brexit day so getting a carte de séjour should be relatively painless. I hear this is not that rare of a situation, there's a lot of stories of f BA LH pilots living in Bordeaux, Lyon etc.
I was just wondering if anyone on here has/is doing it, and how the tax system works. Am I right in thinking, you pay NI in the UK and Income tax in France? and if so, how does it work with the UK taxing at source? and with the whole 'you can't be in the UK for more than x days a year' rule?
Are there any other major obstacles to consider?
Thanks
Firstly sorry if this is in the wrong place/already discussed, I did a search but couldn't find anything.
I'm currently working in the UK and looking to move to France and commute, for various personal reasons. And I ideally want to get this done before the big Brexit day so getting a carte de séjour should be relatively painless. I hear this is not that rare of a situation, there's a lot of stories of f BA LH pilots living in Bordeaux, Lyon etc.
I was just wondering if anyone on here has/is doing it, and how the tax system works. Am I right in thinking, you pay NI in the UK and Income tax in France? and if so, how does it work with the UK taxing at source? and with the whole 'you can't be in the UK for more than x days a year' rule?
Are there any other major obstacles to consider?
Thanks
so getting a carte de séjour should be relatively painless
And getting a carte de séjour will only get you 5 years stay, then a further renewal, then ................... well nobody knows even now what will happen to current carte de séjour holders holding UK passports so don't pin your hopes on it becoming a 'get out of jail free' card or the magic key to continued employment.
And please remember that HMRC are still keen to collect tax from you and have a dual taxation treaty with the French government which will probably still stand after an eventual Brexit.
Last edited by Alsacienne; 22nd Jun 2018 at 15:01.
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Re Taxation - I think you may find that as you are earning in the UK, you will be assessed as 'domiciled' in the UK and will therefore pay UK tax including NI. If so, as you are living in France, you will complete a tax return there but will pay nothing unless your UK tax bill is less than your French tax bill , in which casr you pay the French the diofference. This may change after BREXIT.
French beaurocracy is time consuming with loads of forms (English ones will have to go via an official translator), but I have found it efficient as long as you do not try to short circuit their systems.
Lovely idea, but much better to get a job in France, if you are wanting to live there.
French beaurocracy is time consuming with loads of forms (English ones will have to go via an official translator), but I have found it efficient as long as you do not try to short circuit their systems.
Lovely idea, but much better to get a job in France, if you are wanting to live there.
Carte Sejours to Brits.....fast changing subject. They stopped issuing them to us years ago (just after we arrived) on the grounds that since the U.K. was in the EU issuing them was an unjustified expense. Seems now to be a department by department, prefecture by prefecture “thing”, and we are off to chase up the staff in our local prefecture about this next week.
As for the money stuff...if you are flying for a U.K. company, based in the U.K., resident in France (more about residence in a moment) here is my take on it:
NI......paid in full the U.K. - presently gives you and yours access to the French Health system via the reciprocal healthcare arrangement..next year?
French Social Charges - Not levied on your U.K. salary (because you have paid UK NI on that) but a factor to consider since it is levied on pretty much any other income and it can be significant.
Income Tax: You need to have a look at the HMRC documents on Residency and most especially the Statutory residence test. (it’s not just about spending< 90 days in the U.K., other factors get considered to establish your centre of interest). Forget the word “ domicile” that’s a different subject, you are looking at whether you can be deemed “non-resident for Tax purposes” in the U.K. by HMRC.
https://www.gov.uk/government/public...dence-test-srt
If you do move to France and are deemed “non-resident in the UK...”:
1, You still need to do a U.K. tax return, you will still be liable to income Tax in the U.K., the assessable amount based on that percentage of your duty hours for the year that were spent in the U.K. /U.K. airspace. In v simple terms once established as non-resident you get taxed a notional amount per month through payroll PAYE, Post each tax year HMRC then look at your achieved hours/work, crunch the numbers and either send you a bill for any extra you owe or refund you any excess you have paid.
2. You must also do a French Tax return (apparently not everybody knows that, which eventually leads to tears, oh, and the French tax year is the calendar one, not the Brit April to April one... just to add to the fun)...the folks at the tax office assess all your income, calculate the income tax and Social charges payable in France using whatever the formula is this year and then subtract the income tax already paid to the U.K. (due Double taxation agreement). ATM you get a bill (or several over the year, it depends), for the resultant amount and not a lot of time to pay. The payment system is changing and may end up more like PAYE (for some) in the very near future. Unless you have lots of allowable expenses and/or lots of dependants (family stuff like putting kids through education, grannie or grandpa living in your loft...) the bill can be for a significant amount, OTOH If you have lots of dependent dependents you might get a nice surprise...
I would agree with Philo’s comment that actually French bureaucracy can work quite well...as long as you don’t ignore paperwork and don’t take the**** I have always found officials very helpful.
oh yes....Brexit...nobody knows.
As for the money stuff...if you are flying for a U.K. company, based in the U.K., resident in France (more about residence in a moment) here is my take on it:
NI......paid in full the U.K. - presently gives you and yours access to the French Health system via the reciprocal healthcare arrangement..next year?
French Social Charges - Not levied on your U.K. salary (because you have paid UK NI on that) but a factor to consider since it is levied on pretty much any other income and it can be significant.
Income Tax: You need to have a look at the HMRC documents on Residency and most especially the Statutory residence test. (it’s not just about spending< 90 days in the U.K., other factors get considered to establish your centre of interest). Forget the word “ domicile” that’s a different subject, you are looking at whether you can be deemed “non-resident for Tax purposes” in the U.K. by HMRC.
https://www.gov.uk/government/public...dence-test-srt
If you do move to France and are deemed “non-resident in the UK...”:
1, You still need to do a U.K. tax return, you will still be liable to income Tax in the U.K., the assessable amount based on that percentage of your duty hours for the year that were spent in the U.K. /U.K. airspace. In v simple terms once established as non-resident you get taxed a notional amount per month through payroll PAYE, Post each tax year HMRC then look at your achieved hours/work, crunch the numbers and either send you a bill for any extra you owe or refund you any excess you have paid.
2. You must also do a French Tax return (apparently not everybody knows that, which eventually leads to tears, oh, and the French tax year is the calendar one, not the Brit April to April one... just to add to the fun)...the folks at the tax office assess all your income, calculate the income tax and Social charges payable in France using whatever the formula is this year and then subtract the income tax already paid to the U.K. (due Double taxation agreement). ATM you get a bill (or several over the year, it depends), for the resultant amount and not a lot of time to pay. The payment system is changing and may end up more like PAYE (for some) in the very near future. Unless you have lots of allowable expenses and/or lots of dependants (family stuff like putting kids through education, grannie or grandpa living in your loft...) the bill can be for a significant amount, OTOH If you have lots of dependent dependents you might get a nice surprise...
I would agree with Philo’s comment that actually French bureaucracy can work quite well...as long as you don’t ignore paperwork and don’t take the**** I have always found officials very helpful.
oh yes....Brexit...nobody knows.
Last edited by wiggy; 23rd Jun 2018 at 07:08. Reason: must stop editing
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If you work for a UK Airline, you will be deemed resident due to the rule of 5 or more flights working starting or finishing in the UK. That makes you automatically tax resident in the UK. Sorry for the bad news!
We certainly have a few short haul crew operating out of a U.K. base who are non resident in the U.K. for tax purposes and HMRC ( who do occasionally examine the rosters) seem OK with them popping in and out of the U.K. 5 or more times a month.
:
Hence the ever so polite ask for a HMRC reference..
I know my shorthaul colleagues have to be very very aware of the finer points of the statutory residency tests but I’ve never heard any of them mention a 5 trip rule. I suppose there’s just a chance it’s a very new restriction but.........
Hence the ever so polite ask for a HMRC reference..
I know my shorthaul colleagues have to be very very aware of the finer points of the statutory residency tests but I’ve never heard any of them mention a 5 trip rule. I suppose there’s just a chance it’s a very new restriction but.........
