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Getting your UK pension paid in France

A guide explaining how you can receive UK pensions in France

DISCLAIMER

The following information is intended as a guide only, and no guarantees are made as to its current authenticity. It is, of course, as accurate as possible, in the view of the writer. It is important to note, however, that changes are occurring in the pension system both in the UK and in France, so before acting on any advice or information you receive from this article or elsewhere, it is essential to check out your entitlement with the appropriate bodies. This article hopes to provide useful guidelines, and to supply links to or contact details for government authorities rather than to provide definitive rules.

Pensions in France or the UK - a controversial topic

The topic of pensions whether it be in France or the UK is both complex and controversial. The state of pensions in the UK has been raising heated debate for years now, and with proposed changes in the pipeline, this situation looks set to continue for some time to come. However, what is the situation that you will find yourself in if you decide to retire in France? (Retirement in France, Retirement in Perpignan.)

Retirement in France

France has a great appeal for many who wish to make the most of their retirement years, with its warm climate, calm atmosphere and easy, healthy way of life. What could be better, after decades of hectic running around earning a living in the UK, than to settle for a life in the sunshine, a fresh croissant for breakfast and a glass of locally made wine in your hand as the sun goes down each evening? (Life in France.)

Can you have a UK pension paid to you in France?

This idyllic lifestyle, however, will cost a certain amount of money to sustain, and no one, however frugally and quietly they live, can exist on fresh air alone. Many who retire to France, or who come to France before retirement age, will have amassed some degree of entitlement to a UK pension. The first question they ask then, is whether or not it is possible to have a UK pension paid to them in France, and how this might operate.

Yes, you can have a UK pension paid to you in France

The answer to the first question, is yes. It is perfectly possible (and legal) to have a UK pension paid to you in France if you have an entitlement from the UK and have since become a full time resident in France. It is important in this context to differentiate between state, private or occupational, and government pensions. (Government pensions are largely those paid out on behalf of the civil service and armed forces.) All types are easily transferable to France, but there are some strange differences in the taxation of different types of pension which become important later in this article.

Entitlement to a UK state pension

To be clear about what your individual pension entitlement will be on retirement (as long as you are not within four months of retirement age) you should request a forecast from the Inland Revenue (www.hmrc.gov.uk). There was (May 2006) a government white paper that proposed further changes to the system by which pension entitlements are determined, and details of this are available on www.dwp.gov.uk/pensionsreform. It is strongly advised that you acquaint yourself with these changes and keep abreast of developments as this can determine whether or not you need to pay voluntary class 2 or class 3 contributions.

Boosting your UK pension

If you are still a number of years short of the official state retirement age, it may prove beneficial to make voluntary national insurance contributions to boost your pension when it does become payable. This is a complex and subjective topic, and should be studied with the help of a pensions adviser.

How to claim a UK state pension in France

This procedure is governed by whether or not you have at any stage made any state pension contributions in France. If you have been employed in France since arriving here (Jobs in France), or have set up your own business (Owning Gîtes and Chambres D'Hotes (B&Bs) in France), you will have made compulsory contributions via URSSAF. These contributions will have been generating pension and other social security rights. Your initial point of reference to claim your state pension should then be the French social security office to ensure that you receive the full benefit available. If you last worked and were insured in the UK, you should receive an application form from the UK pension service around four months before you reach retirement age. For details of how to claim through a French (or other European) social security institution you can visit the Europa website, on http://ec.europa.eu/youreurope/nav/en/citizens/living/social-security/index.html.

How is the pension entitlement decided between the UK and France?

The amount to which you are entitled is worked out by each country in which you have worked and paid contributions, and set against the amount to which you would have been entitled had you been in that country full time. The countries involved will decide how much your contributions would entitle you to within their own system, and will send details to any other involved country. You then receive an appropriate proportion of your entitlement from each country.

How can the UK state or government pension be paid if you live in France?

A UK state or government pension can be paid directly into a French bank account, although this may not always be the case with an occupational or private pension (see below). It is also only payable in sterling, so if being paid into a French bank account you will have to pay the conversion charges. It will also have to be paid according to individual regulations and agreements. If you still have a UK bank account and prefer that your pension be paid into this, then this is also possible.

How can UK private or occupational pensions be paid if you live in France?

Private or occupational pensions are often drawn at a much earlier age than the state pension, early retirement unfortunately not being an option under the state system! Most pension providers are entirely flexible about paying your pension to a French bank account, although they are not usually willing to pay the transfer or conversion expenses. If you maintain a UK bank account it may be preferable to build up a more substantial sum and then transfer and exchange currency at convenient intervals.

Taxation of UK pensions in France

This is where things start to get a bit tricky. Government pensions are not taxable in France but are taxed at source in the UK. (As mentioned previously, government pensions are largely those paid out on behalf of the civil service and armed forces.) Private or occupational pensions are taxable in France and can be paid gross from the UK. The UK state pension is treated not as a government pension, but as a private pension, and is taxed in France. All pension income, whether government, private, occupational or state, must be declared on your French income tax return. If this sounds a little contradictory to you, then you are not alone. Here are some points that might help:

a) Private pensions, or occupational pensions, are paid by the pension funds of individual companies. Bizarrely, UK state pensions are treated this way, even though there is no state pension fund.
b) Even though you pay tax at source on government pensions and also declare them on the French tax return, you do not pay tax in France on those pensions. These payments are however used to push any other income you may have into higher income tax brackets.

And what about health care for pensioners in France?

Prior to pension age, you can use form E106 (available from the DSS) to provide temporary (two years worth) health cover while you are living or staying in France. If you have been working in France and paying into the benefits system in place there, you will receive a Carte Vitale which entitles you to a percentage of your health care costs (the same as French nationals receive). The shortfall can be made up by paying into a Mutuelle, or private insurance policy. If you receive only a UK state pension, (or if you will later become eligible to receive an EU pension) you should request a form E121GB, and this will help you to become registered with health care in France. Even after state retirement age you should still consider purchasing a Mutuelle "top-up" policy. Your basic health care provisions will be free, but this will not cover the full cost of treatment. (Health Care in France: a French Hospital Experience.)

The ever changing money markets

The fluctuations of the financial markets and currency values have had a pretty devastating effect on the value of British pensions paid to those who have retired to live in France. Some five or six years ago, the pound was a far stronger currency than it is today (October 2010), and pensions paid in Sterling went a lot further to cover living expenses in France than they do now. Unfortunately there is not a lot you can do about that, if your pension is paid to you from Britain it will be paid in Sterling and you cannot control its value in Euros. However, there are still ways of saving some money.

Further information on UK pensions

The subject of pensions is complex, and subject to change. For up to date information, ask for leaflet SA29, "A Guide to National Insurance Contributions Benefits and Medical Services in the European Economic Area". It is available from the Department for Work and Pensions (www.dwp.gov.uk).

Additional articles which may be of interest:

Tax in France
Banking in France
Living in France
Letting property in France

About the author

Joanna Simm moved to the Languedoc area of south-west France in October 2004 having found her property through French Property Links. Information in this article was also provided by Rob Hesketh.

your questions...

1. A question to all about self-employment and pensions (added 22/4/09)...

Since February, when the UK Pensions Service wrote to me, I have been trying unsuccessfully to start the process somewhere.

The UK Pension Service won't deal direct with me, because since leaving the UK twelve years ago I have been self-employed in France and must therefore, in their eyes, contact the "pension institution in that country". But which institution?

Contrary to what your article suggests, the URSSAF do not handle my pension contributions, which are dealt with by the CIPAV (Caisse Interprofessionelle de Prévoyance et d'Assurance Vieillesse), who are not concerned with the main state pension scheme at all and therefore don't want to know.

The majority of pensions (mainly for ex-employees) are handled by the CRAM on behalf of the CNAV (Caisse Nationale d'Assurance Vieillesse) and this would seem to correspond to the UK Pension Service; indeed the CNAV confirm on their website that one must apply for one's pension through the EU country in which one is living, if one has worked there at any time. However, the regional offices of the CNAV, i.e. the CRAM, don't want to know on the basis that I have never paid any state pension contributions (i.e. through the CRAM) in France...

I am now within eight weeks of retirement age (65) and no one, in either country, seems to want to know: presumably because I don't fall into the broader category of having been an employee in both countries.

The situation is all the more absurd because I continued to pay voluntary contributions in the UK after moving to France, until notified by the UK Pensions Service that I now qualified for a full pension; I now find myself deprived of it because the responsibilities have not been spelt out properly in European and national legislation.

I cannot be the only person from the UK now working in France who finds himself in this situation. Is there anyone who has any further information for those who have been self-employed in France, please? I'd be most grateful.

Our reply, courtesy of a visitor to the site (added 2/9/09)...

Kate Storey has kindly sent us information regarding this question:

"I too am having a battle royal with CRAM, CIPAV, et al... despite actually having a claim via the CRAM. I was lucky (or unlucky) enough to be employed in France before I became self-employed, however, having applied for my pension nearly a year ago I am still getting the run-around.

The CIPAV is part of the RSI (Régime Social d'Indépendants) and the RSI and CRAM should work hand in hand - ha ha!

The CNAV is not for us at all - that is for the French in other EU countries who are allowed to claim their pension direct from France - one rule for them, another ...

May I suggest that you download the "Demande de retraite personnelle" from your local CRAM site, because whatever the CRAM state, they do have a duty to process a pension request from the self-employed (and share and collect information from all the special pension "regimes") as they cover the RSI and there is a tick box for the CIPAV on this form.

You should complete the RSI section under the personal details part of the form "Votre N° RSI COMMERCANT" (crossing out "commerçant" and inserting "non salarié") and under "Quel régime..." on the same page, complete the "régime non salariés agricoles" crossing out "agricoles", then under "Votre activité professionnelle en France", tick the Profession libérale box and enter the dates.

You should also have recourse to the SS Commission de recours amiable, site:

http://www.legifrance.gouv.fr/affichCodeArticle.do?cidTexte=LEGITEXT000006073189&idArticle=LEGIARTI000006748158&dateTexte=&categorieLien=cid

Another text can be found on:

http://www.cram-nordpicardie.fr/Retraite/VosDroits/P06LesRecoursContentieux.html

At European level there are these two:

http://ec.europa.eu/youreurope/nav/en/citizens/services/eu-guide/enforcing-rights/index_en.html

http://www.legislation.cnav.fr/web/recherche/rech_frame_theme.htm"

I hope this information will be of use.

An update to question 1 (added 15/10/09)...

Thank you very much for getting back to me, with your interesting and helpful letter.

Since we were last in touch, things have moved on a little, but in a sense not much! The CIPAV did finally accept responsibility for making the first move (I think your correspondent's success with the CRAM may be because he has also been salaried in France, they persist in denying any responsibility for me and this seems to be confirmed by the Pensions Office in the UK and also the CLEISS (the European liaison centre for social security entitlements), who finally replied after more than four months!

However, just before the end of July, I was contacted by phone by the CIPAV to say they were "concerned" that the UK Pension Service had not got back to them, they were resending my documents, would send a copy to me for reference, and would endeavour to get payment of the French element of my entitlement in hand before they moved offices in mid-August, something they anticipated would cause "problems". Well, it is only just September, but three months after my entitlement began, there is still no sign of any French money... and of course the CIPAV are busy settling into their fine new offices and sorting their records...

I am less surprised than they by the lack of response from the UK Pension Service, because when I saw the copies of the forms sent, very little of the information I had provided on the CIPAV forms had been transferred to the standard European forms, and it would have been quite difficult or at least lengthy for the UK Pension Service to work out who the form related to (no UK reference, etc). Since I had been sent a photocopy of the forms, I added the missing information in coloured ink and sent the copies with a covering letter to the UK Pension Service.

As it happened, the UKPS had meanwhile contacted me in writing at about the same time, saying they were concerned at the lack of response from the French side... and proposing to start paying my UK entitlement directly to ensure I would not miss out. This despite the original "we can't deal direct" attitude - it would have been so much easier for all in square one! Bless them, unlike the CIPAV, the UKPS payment came through for the 1st September!

So, in the short term I'm getting some, though not all, of what I should be getting, though I still have no idea of what I should finally get from both sides! There is no sign of any French payment at the moment, I doubt if there will be now until October at the earliest!

I'll keep you posted, if it would be of interest, and have offered my professional services to the CIPAV as interpreter/translator in the light of their stated difficulties with European forms! Somehow, I don't think they will take that up!

Thank you for the links to the Commission de recours amiable site, that may yet be extremely useful, as may the others!

2. A question about possible supplements to a pension (added 21/5/09)...

I claim a UK state pension in France and have heard rumours recently that it is possible to claim a supplementary pension from the French Government if your income falls below a certain value at the age of 65. Have you heard anything about this, I'm having difficulty ascertaining correct info from France. If so, would you know what the "certain value" is and also can this be claimed at 60 for a woman?

Jo Rhodes, editor of French Property Links, replies...

Thanks for contacting us. I understand that pensioners on a low income may be eligible for an allowance from the French Government, from the age of 65 (or 60 if disabled and unable to work.) This is the "allocation de solidarité aux personnes âgées" (ASPA) benefit, and can only be claimed by residents of France, and those registered for income tax in France.

The benefit can be claimed if your income is below 648 Euros/month for a single person, or 1136 Euros/month for a couple, and is done via your Mairie, though you must actually apply to the Caisse des Dépôts for this.

A visitor to the site also comments (added 2/9/09)...

I think you will find that this does not apply at age 60 unless disabled, etc., and the amounts quoted should not be used for property owners as I believe they include a rental allocation.

3. Questions about pensions (added 8/9/11)...

I am retiring in October this year when I will draw my state pension. I have been self employed in France for three years under the micro enterprise system. What I should be entitled to is three fortieths' from the French pension fund. My questions are:

1. I will still be below the minimum French level so should I contact the Caisse des Dépôt?
2. Do they take into account any saving that you may have? And if so at what level?
3. I also have a private pension that I was going to defer for another five years. Do they also take this into account?

Jo Rhodes, editor of French Property Links replies...

Thanks for contacting us, though as I am not an expert in such matters, I'm afraid I don't know the answer to all your questions. I would certainly check with your Mairie or Caisse des Dépôts to see if you are entitled to any benefits, and also check with them about savings and private pensions. You could ask a legal advisor too, perhaps using the following page on our site:

http://www.frenchpropertylinks.com/frenchlegalservices.htm

(Charges are not always made if answers are quick and easy.)

4. A question about tax on a state pension (added 30/10/12)...

Hi - I receive state pension ( in the UK ) of £107.58p a week. Will this be subject to tax in France and at what percent?

Jo Rhodes, editor of French Property Links replies...

Thanks for contacting us. Though as I am not an expert in these matters and there are many issues which have to be taken into account when working out tax, I would suggest you contact a legal/financial/tax advisor for accurate advice.

5. Another question about tax and pensions (added 30/10/12)

We are pensioners who have lived in France for the past four years and for the first two we did not have to pay tax, but last year and this year we had to pay tax. As our pensions are taxed in England we thought we did not have to pay tax here in France and this was borne out by the first two years. As we have paid tax these last two years we are wondering if we should stop paying tax in England and have it all paid here in France. But we have no idea at all on the tax systems and would like some advice. Please can you help us. We have telephoned and written to England but they just send us the forms to stop English tax and do not offer any assistance. Hoping you can give us some advice and help. Thank you.

Jo Rhodes, editor of French Property Links replies...

Thanks for contacting us, though I would suggest that as I am no expert in these matters, you contact a tax or legal advisor. Perhaps asking your question using the following page on our site:

http://www.frenchpropertylinks.com/frenchlegalservices.htm

Fees are not always charged, if the question warrants a quick answer.

6. A question about sorting out a French pension and which form to use (added 30/8/13)...

I do not seem to get anywhere with my French pension. I am suppose to send a form stipulating that I am under the English social security so I do not have to pay health insurance in France (CSG/CRDS/CSA) being resident in the UK. Which form I do not know!! Would you be able to help me as I am entitled to receive a pension in France and the amount will differ if I am not able to send this certificate from the national health. Thank you for your help as I have been phoning all day to deal with this issue.

Jo Rhodes, editor of French Property Links replies...

Thanks for contacting us. I'm afraid I am no expert in these matters so I would suggest you contact a pensions advisor, or if this is about your UK State Pension, have you tried contacting the International Pension Centre, unless this is who you have been calling all day? Details are as follows:

International Pension Centre
tvp.internationalqueries@thepensionservice.gsi.gov.uk
Telephone: +44 (0)191 218 7777
Textphone: +44 (0)191 218 7280
Monday to Friday, 8am to 8pm

As mentioned in our article, for details of how to claim through a French social security institution you can also visit the Europa website:

http://ec.europa.eu/social/main.jsp?langId=en&catId=860

Or perhaps a company such as Help in France could offer advice (http://www.help-in-france.co.uk/#)?

7. A question about a pension from national service (added 27/5/14)...

I was in the French army for my national service in the 1970s. I am French by birth but lived mostly in Jersey and Britain. Would I have a small pension off France for these two years of active service?

Our reply...

Thanks for contacting us. I'm afraid I don't have a definitive answer for you, but I would think that any pension you may be entitled to may be so small, it might not be worth the trouble of getting it, if indeed you are entitled to anything. I'm sorry not to be of much help. Perhaps talking to a pensions advisor would be worth while.

8. Question about tax on pensions in France (added 2/12/14)...

Hi - I am thinking to come to live in France (Menton). How much tax would I pay on my pension? Can I claim for my wife? Thanks.

Our reply...

Thanks for contacting us. I'm afraid that as I am no expert in pensions or tax, I can only suggest you talk to a pension, tax or legal advisor. You could perhaps ask your question using the following page on our site:

http://www.frenchpropertylinks.com/frenchlegalservices.htm

Fees are not always charged, if the question warrants a quick answer.

Or you could check with BDO Limited. They provided much of the information in our tax articles. Contact details are as follows:

Tel: +44 1481 724561
Fax: +44 1481 711657
Email: french.tax@bdo.gg
Website: www.bdo.gg - click on French Tax

9. A question about where to claim UK and French pensions (added 10/3/15)...

I am entitled to my state pension on 03/09/2015. I will also have an extremely small French pension because of some work under the CESU scheme (ARRCO) retraites complentaires of about 400 Euros per year. The UK people say I have to claim both pensions in France but where and how do I claim? Could I claim these pensions both separately in France and England?

Our reply...

Thanks for contacting us. If you are resident in France, I understand you should claim both pensions in France, but this does depend on whether you have worked in France or not. Our article above does go through what you need to do in order to claim. Should you need further information, you could look at the EU website (www.europa.eu) and contact them if need be. And indeed the UK Government website (www.gov.uk/state-pension-if-you-retire-abroad/how-to-claim).

10. A question about tax codes (added 29/10/15)...

Hi - my wife and I have been living in France for a number of years and both have government (teachers) pensions. We now both have state pensions and when they arrived the British tax office pushed up our teachers pension tax rate to account for our state pensions. They sent these tax statements to our home in France so there was no doubt we were living in France. We have always had a nil tax return in France until this year. Should the British tax authorities not have changed our tax codes, because for this year (with the advent of my state pension) we owe 1200 Euros having paid the equivalent of 4000 Euros in England?

Our reply...

Thanks for contacting us. Though as taxes and pensions can be complicated affairs and as I am not a tax or pensions expert, I can only suggest that perhaps you speak to the UK government Pension Centre for their advice. The details are as follows:

International Pension Centre
tvp.internationalqueries@dwp.gsi.gov.uk
Telephone: +44 (0)191 218 7777
Textphone: +44 (0)191 218 7280

11. A question about possible health/pension benefits (added 29/10/15)...

Hello my mother who is based in England and 82, is considering moving close to myself (her son) and my wife and daughter in Chambery in the French Alps. We would like to know if she is entitled to any French health /pension benefits etc as she only has a basic state pension in the UK and has osteoporosis and has difficulty walking. Any advice would be very welcome.

Our reply...

Thanks for contacting us. Health care in France is a minefield, especially for those with health issues, so I would suggest you call the NHS Overseas Healthcare Team on 0191 218 1999 to get the best advice. Or you could try the English speaking CPAM (French health care and social security office) help line 0033 (0)8 20 90 42 12.

For further pension advice, I would suggest that perhaps you speak to the UK government Pension Centre. The details are as above.

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