Living in France working in Europe

[Daley]

   Hi

Is anyone out there living in France the weekend and working in the EU during the week?  I am considering this and wondered if anyone was able to offer advice on health(my wife will live in France full-time), tax, banking etc  We are looking to buy a house however I would be paid in sterling but will look into having a french mortgage.  Is anyone else living this lifestyle that can offer advice?

Regards

Daley

[Ian]

I'm not sure if I am specifically living this lifestyle - but I'm close.

I live here in France and own a British Ltd company.  I travel back to the UK once or twice a month for a day or two to keep things ticking along.  I draw a dividend income from my company which is in sterling and is taxed here (quite favorably). I draw a small salary (below my personal allowance) which is subject to tax in the UK and is declared here under the double taxation system.

Although I don't have a mortgage on my home, I have 3 investment properties in France each with French mortgages - these were not difficult to arrange (I also have investment property in the UK with a UK mortgage - this proved to be more difficult to change/remortgage once my lender realised I was resident in France...still sorted it out eventually though).

Regarding health - there are forum posts here that should sort you out. Where are you moving from (I guess it is from the English speaking World) - you may find that there is a reciprocal healthcare arrangement with your "home" country that should last you the first few months here until you can get yourself into the system (that's what us Brits enjoy).

All the best,

Ian

[Ian]

Just seen you are living in Germany - I would guess that there is a reciprocal healthcare system between the 2 states.  Sorry about the "English speaking World" assumption.

Ian

[Pierre ZFP]

I may be able answer part of this.  I live/work/bank/pay taxes in Luxembourg and head off to La Belle France most weekends, no mortgage on French house.  The rest of the family is in the UK - its complicated! - Anyway. I am paid and pay tax here in Lux as I said and I'm happy to do so as the rates are low compared to UK or France, this will change when I eventually relocate to France.  As for health, most things are covered in Lux and there are reciprical arrangements for emergency care in other EU states.  I have top-up insurance here but although I know it doesn't cost much, I can't for the life of me remember exactly how much, I just know its a lot less than it would be in France or Germany.   Anything specific I may be able to answer?

[andyh4]

The OP is clearly covered by his own health insurance in Germany for emergency care* only.  The question arises as to the status of his wife who is residing permenantly in France - is she still covered under his German insurance or must she apply separately for cover in France?  Is she also only covered for emergency care or does she get full cover for minor problems?  I guess the German Health Insurance company is the first place to ask. 

Let us know how you get on since I may also be in this position shortly.

 

*and that is the key issue.  Reciprocal rights are for emergency care ONLY.

[Daley]

Hi Ian

Many thanks for your posting. My situation will be a little different in that I will be employed by a UK company and paid in sterling into a UK bank.  I have read that a lot of people are travelling every week from Bergerac to the UK to work, so I was wondering how they manage this in terms of tax etc.

I will keep researching.

Cheers

Dale

[Will]

If you are actually physically commuting and working in Britain (at least for most of the time) then your situation is relatively common, and quite simple.

You will be taxed and pay NI in Britain. As your main home (and family/dependents) are in France, you also qualify as French tax resident which means that you declare your income in France too, but unless you have other income arising in France, you will almost certainly have no extra tax to pay there. As far as French health care is concerned, there are two possible scenarios, depending on your circumstances, either of which you have to sort out with HMRC and DWP. You will receive either an E109 which will cover your family in France, and you will use the EHIC for your visits, or you will get a 'worker's' E106 which will cover you all in France.

A French lender will lend based on your income and other outgoings - as long as this is reasonably secure it is irrelevant where it originates (at least in our experience). You will need a bank account in France for paying bills etc, and an account in Britain to receive your salary. There are various simple ways to arrange a regular transfer from one to the other.

If you are working in Germany however, I think this will have to be sorted out between your employer and the German authorities as to where you actually pay tax and health charges, and thus who covers you personally and provides the E forms, but the basic principles are Europe-wide and should remain the same.

If the work is of relatively short duration (say up to two years, though if Germany is involved there may be a different limit) then you could be covered via an E101 form issued via your British employers which would be valid throughout Europe, and thus solve a lot of problems.

It can get more complicated tax and health care wise once you, or a family member, starts carrying out a significant amount of work in France.

[Ian]

Great comprehensive post Will.

Are you sure about the NI contributions?  I think NI here in France is based on "world wide income" not just (but including) "salary" - and you may derive "income" from outside France (in the UK say) that could still be subject to Social Contributions here(France).

NI in the UK is broadly a salary thing.

I have often tripped myself up with the distinctions between "salary" and "income" - sometime when I say "I get paid ..." it is too imprecise.   -  with income potentially being derived from "Capital Gain" (buying and selling stuff) , "investments" (stock dividends), "property" (rental of rather than buying and selling), "salaries/wages" et al and all being treated slightly differently - it is (sadly) the kind of things that gets the international tax advisors wringing their hands with glee!

[Will]

Ian, yes, you are right. That is why I included a couple of caveats about carrying out work in France or income derived from outside Britain. There are of course a few situations where income may not be liable to tax in Britain, but will be in France and I omitted to mention those. If the original poster's household income originates solely from employment in Britain, then he should not have any additional liability. Even if there is other household income that affects the 'worldwide income' on which you are taxed and pay social contributions you may not have extra to pay. For instance, my own income is taxed, and NI paid, in Britain. Mrs Will is salaried in France - she pays social contributions in France. We pay a small amount of tax in France (based on our combined incomes, less credit for tax I have paid in England). There is no additional social contribution.

Also, don't confuse the social contributions arising from your everyday income with the so-called 'social charges' (i.e. CSG, CRDS, PS) that are applied to unearned income such as interest on savings. This is assessed separately. Once there is any significant extra income, whether from interest, dividends, rentals or whatever, then I would strongly advise people to consult an accountant.

[andyh4]

[quote user="Will"]

If you are working in Germany however, I think this will have to be sorted out between your employer and the German authorities as to where you actually pay tax and health charges, and thus who covers you personally and provides the E forms, but the basic principles are Europe-wide and should remain the same.

[/quote]

 

Will are you sure about that?  The fact that Germany does not have a state health service like the Uk or France, and that everything is done through insurance companies raises questions in my mind as to who issues and whether the "standard" E forms are available.  If you have some definitive info I would be grateful.

[Will]

No, sorry, I don't have any specific experience of Germany. No two countries seem to treat the E forms identically, even though the basic principles are indeed founded in European agreements. There will usually be one of the large selection of E forms - such as the E101 - that can be issued to workers posted overseas, which is what I was talking about, which shows the entitlement of workers to use the foreign health system and enables the foreign system to reclaim costs from the worker's own health assurance provider. Things often work quite differently for non-workers, such as state pensioners and the early retired. Having a 'privately' funded health system does not necessarily preclude the issue of E forms.

After all the French system is a sort of hybrid of a full state system, like the NHS, and a private system. Although there is central control, the actual primary health assurance providers are along the lines of regional public companies (the CPAMs - for salaried and non-workers) as well as a mix of primary health insurers covering the independents, many of which are private companies and 'mutuelles'. Plus the providers of complementaires of course, but that just complicates things even further.