UK resident in France: where do I pay my taxes?

Where do I pay my taxes based on residence as an UK resident in France?

British citizenship and tax residence are different

A British passport establishes nationality. It does not, by itself, require you to pay UK income tax on everything you earn while living abroad.

You can be a British citizen and French tax resident, a UK tax resident temporarily staying in France, or resident under both countries’ domestic rules. Being both British and UK tax resident does not create an additional layer of worldwide income taxation because of your citizenship.

Likewise, a visa or residence permit concerns your right to live in France. Your tax position requires a separate assessment.

How France and the UK assess residence

France examines whether your household or main place of residence, principal professional activity or centre of economic interests is there. You do not necessarily need to spend a full year in France to become tax resident. A settled household in France can matter even when you travel extensively.

The UK applies the Statutory Residence Test. It considers automatic overseas and UK tests, followed where necessary by a test combining UK connections and days spent there.

Consequently, spending fewer than 183 days in the UK does not automatically establish non-residence. Your work, accommodation and family connections can also matter. Residence must be assessed for the relevant tax year rather than assumed from your address.

Where do I pay my taxes as an UK resident in France if both countries claim residence?

Applying the treaty’s residence tests

If both countries regard you as resident under domestic law, the treaty determines your residence for treaty purposes.

It first examines where you have a permanent home available. If you have one in both countries, it considers where your personal and economic connections are closer. Further tests examine habitual abode, then nationality; unresolved cases require agreement between the authorities.

British citizenship therefore becomes relevant only at a later stage. It does not override an established home and closer connections in France.

Distinguishing residence from reporting obligations

Treaty residence does not mean every item of income is taxable exclusively in that country. Different provisions apply to employment, business profits, pensions and property.

You may also need to submit information or returns in both countries. Declaring income twice is different from paying full tax twice. The treaty provides mechanisms to relieve double taxation, but the appropriate relief must be identified and claimed.

For example, a French resident with a UK rental property should assess the rental income separately from salary earned while working in France.

UK resident in France: where do I pay my taxes after moving?

Moving less than a year ago

The first year often requires the most careful review. If you establish French tax residence on arrival, your French resident reporting generally covers the relevant income from that date through 31 December. French income received before arrival may also require reporting.

Your first return is normally submitted the following year. Moving late in the year does not automatically remove this obligation.

In the UK, split-year treatment may separate a resident period from an overseas period. It is conditional, so your moving date alone does not establish entitlement.

Moving one year or ten years ago

There is no general tax switch on your first anniversary. You still need to establish your residence for the applicable periods.

After ten years of settled living and working in France, French residence will usually be the practical starting point. Nevertheless, UK income can remain relevant, and changed circumstances can affect residence.

France uses the calendar year, while the UK tax year runs from 6 April to 5 April. The same move therefore falls into different reporting periods.

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UK resident in France: where do I pay my taxes on employment income?

Working in France for a French or UK employer

For someone who is French resident for treaty purposes, ordinary employment performed in France is generally taxable there.

This also applies when you work remotely from your French home for a UK employer. The employer’s address, payment currency and bank account receiving the salary do not determine where you performed your duties.

UK payroll deductions should therefore be reviewed against your actual liability. They are not proof that France has no taxing rights. Your employer may need to examine payroll arrangements in both countries.

Working physically in the UK or across both countries

If you live in France but perform duties in the UK, the UK can generally tax the associated employment income. For work divided between both countries, the allocation usually follows where duties were performed.

Keep records showing working days, travel and work locations. These help explain why part of your remuneration relates to France and another part to the UK.

For a non-UK resident, HMRC guidance confirms that employment taxation generally concerns the days worked in the UK.

Understanding the short-stay exception

A treaty exception may prevent the country visited from taxing employment income if all relevant conditions are met:

• Presence there does not exceed 183 days within the relevant twelve-month period.
• The employer is not resident in that country.
• The remuneration is not borne by the employer’s permanent establishment there.

A short visit alone is insufficient. A French resident working in the UK for a UK employer will generally fail the employer condition. This exception also differs from the tests establishing tax residence.

Remaining UK resident for treaty purposes

If treaty residence remains in the UK, the UK normally taxes worldwide employment income. France may still tax duties performed there, subject to the employment exception and treaty relief.

The correct sequence is therefore residence, work location, applicable exception, then relief. Starting with whichever country already deducts tax can produce an incorrect result.

Where do I pay my taxes on other income as an UK resident in France?

Self-employment and UK clients

A sole trader established and working in France generally pays French tax on business profits, even when clients are British. Client location alone does not create a UK business presence.

A UK permanent establishment can change the outcome. Operating through a UK limited company also requires a separate assessment: company profits, salary, dividends and directors’ fees do not necessarily follow identical rules. Managing that company from France raises further questions.

Private pensions, State Pension and government-service pensions

For a French treaty resident, regular UK private and workplace pension payments are generally taxable in France. The UK State Pension is also generally taxable there.

Government-service pensions have separate rules and commonly remain taxable in the UK for a British recipient living in France. The pension’s precise classification matters; the State Pension is not a government-service pension simply because the government pays it.

Pension lump sums require a specific review rather than an assumption based on regular payments.

Rental income and property ownership

The country where a property is located can generally tax its rental income. A French resident letting a UK property may therefore have UK obligations while also reporting the income in France and applying treaty relief.

French property rent is generally taxable in France. Owning a French property can also create property-related tax obligations independently of income-tax residence. Taxe foncière and income tax are separate issues.

A property sale needs its own capital-gains assessment. Rental-income treatment should not automatically be carried over to the sale.

How do you declare income and pay tax in France and the UK?

Preparing your French return

Begin by confirming your residence commencement date and obtaining the details needed to file with the French tax authorities.

Organise income by category rather than grouping everything as “UK income”. Salary, pension payments, business profits and rent can require different treatment and supplementary declarations.

Your first resident return generally involves the main income-tax return and relevant appendices, including foreign-income reporting where appropriate. Foreign-account reporting is another obligation to check separately.

A useful preparation file includes income statements, pension descriptions, rental accounts, travel records and evidence of tax deducted abroad.

Reviewing UK reporting and claiming relief

Depending on your circumstances, you may need UK Self Assessment and residence information. Non-residents filing a UK return should check the appropriate submission method and residence pages.

Relief is not achieved merely by telling one authority that the other has collected tax. The income must be correctly classified, and the relevant treaty treatment applied.

Where deductions exceed the final liability, a repayment or adjustment may be necessary. Do not assume payroll withholding equals the final tax bill.

Paying tax and checking social security

Once liability is established, payment is a separate practical step. French tax can involve withholding, instalments and an adjustment after the annual declaration. The French authorities provide online payment guidance, including arrangements for non-residents paying French taxes.

Social-security contributions and employer obligations also require separate consideration. An income-tax conclusion does not automatically resolve healthcare affiliation, National Insurance or French contributions, particularly for remote workers and temporary assignments.

Getting advice on your UK–France tax position

The most useful review brings together your moving date, homes, family connections, work locations and income sources. It should establish both where you must report income and how each country’s taxing rights interact.

For someone settled in France and working there, French taxation is generally central. Retaining UK income adds category-specific obligations rather than making the entire position automatically British.

Azmy Avocat can be contacted to discuss the legal questions arising from your move and identify the advice appropriate to your circumstances. Reviewing the position before changing payroll, drawing a pension or restructuring a business helps ensure those decisions reflect your actual residence and obligations.