If you are a UK expat living in France, your financial situation involves both UK and French rules. Your UK pension, investments, tax position and estate planning all need to be considered in the context of both jurisdictions. This guide covers the key questions worth asking — it does not provide personalised tax advice.
Your UK pension
Your UK pension remains yours when you move to France. You can generally leave it where it is — you do not have to transfer it.
Key questions:
- Can I leave my UK pension where it is? Yes, in most cases. See our guide: I Live Abroad – What Happens to My UK Pension?
- How are pension withdrawals taxed in France? This depends on the UK-France double taxation treaty and your French tax residency status. French social charges may also apply. Seek specialist tax advice.
- Should I transfer my UK pension? Not necessarily. Leaving your pension unchanged may be perfectly appropriate. Never transfer on the recommendation of an unregulated adviser.
- Can I keep my SIPP? Yes. Whether you can continue contributing depends on UK relevant earnings.
Source: GOV.UK — Tax on your private pension contributions
Existing UK investments
Your existing UK investments (ISAs, general investment accounts, shares) remain yours but their tax treatment changes when you become a French tax resident.
Key questions:
- Are my ISAs still tax-free in France? ISAs are a UK tax wrapper. France does not recognise the ISA wrapper, so investments within an ISA may be subject to French tax. Check with a French tax adviser.
- How are UK dividends taxed in France? UK dividends may be subject to French income tax and social charges. The UK-France double taxation treaty determines which country has taxing rights.
- Should I move my UK investments to France? Not necessarily. Keeping UK investments may be appropriate, but you need to understand the French tax treatment.
Can your existing adviser continue advising you?
Many UK financial advisers are only authorised to advise UK residents. When you move to France, your adviser may no longer have the regulatory permission to provide advice to you.
Key questions:
- Is my UK adviser regulated to advise clients in France? Ask them directly. They may need to be regulated by the AMF (Autorité des Marchés Financiers) or hold EU passporting rights.
- If not, how do I find an adviser who is regulated in France and understands UK assets? See our guide: How Do I Find the Right Financial Adviser When Living Abroad?
French residence considerations
When you become a French tax resident, you are generally taxed on your worldwide income. French tax residency rules are based on several criteria, including where your main home is, where your professional activity is, and where your centre of economic interests is.
Key questions:
- Am I a French tax resident? This depends on the French tax residency criteria. If you spend more than 183 days per year in France, you are likely a French tax resident.
- What is my UK tax residency status? The UK uses the Statutory Residence Test. You may be a UK tax resident, a French tax resident, or both (in which case the double taxation treaty tie-breaker rules apply).
- Do I need to file tax returns in both countries? Possibly. Check with a cross-border tax specialist.
Source: GOV.UK — Tax if you leave the UK to live abroad
Currency
If you have income or assets in GBP but your living costs are in EUR, currency fluctuations can have a significant impact on your financial position.
Key questions:
- How do I manage GBP/EUR currency risk? Consider a currency management strategy, including regular transfer arrangements and forward contracts.
- Should I hold investments in GBP or EUR? This depends on your spending needs and long-term plans. A regulated adviser can help.
Property
If you own property in the UK and/or France, there are tax considerations in both countries.
Key questions:
- How is my UK property taxed if I live in France? UK property may be subject to UK capital gains tax on sale, and France may also seek to tax the gain. The double taxation treaty determines which country has taxing rights.
- If I buy property in France, what taxes apply? French property purchase taxes (notaire fees, stamp duty) and ongoing property taxes (taxe d'habitation, taxe foncière) may apply.
- How does French property affect my estate? French forced heirship rules may affect how your property is distributed on death. See the estate planning section below.
Estate planning
France has forced heirship rules that may affect how your assets are distributed on death. This is particularly important for UK expats whose existing wills may not align with French inheritance rules.
Key questions:
- Do I need a French will? Possibly. A French will can help ensure your French assets are distributed according to your wishes, subject to French forced heirship rules.
- How does French forced heirship work? French law reserves a portion of your estate for your children. This can affect how you distribute your assets.
- Does my UK will still work in France? A UK will may be recognised in France, but French forced heirship rules may override some of its provisions. Seek specialist estate planning advice.
- What about inheritance tax? France has its own inheritance tax rules, which differ significantly from UK inheritance tax. The UK-France double taxation treaty may affect which country's rules apply.
Source: GOV.UK — Inheritance tax and double taxation relief
Returning to the UK
If you return to the UK, your tax position will revert to UK rules. However, there may be complications.
Key questions:
- What happens to my French assets if I return to the UK? They remain yours, but their tax treatment will change.
- Do I need to notify anyone when I return? You should notify HMRC and the French tax authority of your change of residence.
Moving elsewhere later
If you move from France to another country, your financial situation will change again.
Key questions:
- Can my adviser continue advising me? Your adviser may need to be regulated in your new country of residence. Ask before you move.
- What happens to my French tax position? Your French tax residency will end, but you may have French assets that continue to have French tax implications.
Finding an appropriately regulated adviser
To find an adviser who understands both UK and French rules:
- Check they are regulated in France — by the AMF or through EU passporting
- Ask about their experience with UK expats in France
- Ask about their knowledge of both UK and French tax rules
- Check they understand UK pensions and investments
- Verify their regulatory status on the AMF register
Link Independent is a curated introduction service that helps expats and internationally mobile clients connect with appropriately regulated financial advisers based on their circumstances. Find an adviser or use the Expat Planner to get started.
Finding the right professional
Different circumstances can require different types of professional help:
- Financial adviser — for pensions, investments and financial planning. See our guide: How Can I Check Whether a Financial Adviser Is Regulated?
- Tax professional — for French tax residency, filing obligations and UK-France double taxation treaty questions
- Legal professional — for wills, French estate planning (including forced heirship) and property legal matters
- Mortgage specialist — for property financing across borders
- FX provider — for GBP/EUR currency transfers and managing exchange rate risk
Understanding the total cost of advice is important before you commit to any arrangement.
Link Independent can help identify appropriate professionals from its network based on your circumstances. Find an adviser or use the Expat Planner to get started.
Summary
- Your UK pension remains yours — you do not have to transfer it
- Your UK investments may be taxed differently in France
- Your existing UK adviser may not be able to continue advising you
- French tax residency rules are based on several criteria
- French forced heirship rules may affect your estate planning
- You need an adviser regulated in France who understands UK assets
- Always seek specialist cross-border tax and financial advice before making decisions
This guide does not provide personalised tax advice. Always consult a regulated adviser and a qualified tax professional.