UK and French State Pension amalgamated? Paid by one country?

[Woodrup]

I have been receiving my UK Pension for a couple of months, paid direct to my French bank. I am in the process of claiming my French State Pension, about €40 per week after working here 10 years. They say they are in process of validating my UK contributions (Nat Ins presumably). This confused me. Then I read somewhere that the two Pensions could be amalgamated and the total paid by one country (I was short on NI contributions and receive £159 p.w.).

Does anyone know about this? Could my UK Pension be taken over by and paid with the French one in Euros? Therefore avoiding future £/€ exchange rate losses .

[NormanH]

I receive them separately

In the past you  were supposed to claim them through the French system and a total was calculated, but that didn't happen in practice for me, as I

already had  one of them in place before the other became due.

My French ones  are paid monthly but the OAP is four-weekly, sourced in sterling and converted into Euros by the paying bank. I don't know how that would work if they were combined.

Once you have  a French pension France will be responsible for paying for your health care, and you may become liable to pay CSG etc on your total income, depending on how much you have, since the UK S1 no longer applies.

[idun]

Yes, we have been through this, they confer with the DWP and make sure that you have enough years for a full pension according to french rules.

The calculation is done  pro rata. You will need about 165 trimestres in total from both countries and then the 10 years, ie 40 trimestres will be paid based on your french state pension payments. It is so that they can actually pay this, that they check up.

Have you paid  complementaire? Can you apply for that too?

It was never suggested that our pensions could be amalgamated. Both are paid separately.

As NH said,, if you are living in France, you will not be eligible to get an S1 but will pay any  cotisations due on your french pension, as other french pensioners do.

[nomoss]

The rules for claiming and receiving pensions from the UK together with EU countries are HERE

Entitlement to a French pension may also affect the amount of pension paid by the UK if enough payments were not paid in the UK for a full pension there. The UK Pension Service will advise on this.

As NormanH pointed out, because the effects on taxation in France when claiming a small French pension could outweigh the benefits, it is wise to study the rules, and make the necessary calculations, before claiming it.

[Woodrup]

Thanks NormanH

I have been in the French health care system since moving here, presumably deductions from wages paid for it, so now I will be covered automatically? That's something I hadn't thought about. I also have a Mutuelle insurance.

What is the S1?

I exited the UK Tax system when I moved here, I completed the relevant form.

In fact I have just searched my HMRC account online to see if I still have a code number, I need to activate a private pension (Bond 32) and was wondering if they'll tax that at source. I'll telephone the private pension to find out.

[Woodrup]

Thanks idun

I have 38 French trimestres but last years are missing at the moment.

Yes I have applied for the complementaire retraite too. I returned an envelope of stuff they asked for, verification of work

history, missing trimestres etc in March, with a tracking number .....

It got lost in the post, one of the most important envelopes I've posted

since living here.

[Woodrup]

Thanks for that link nomoss

I see HMRC say -

'You can also count relevant social security contributions made in EU countries to meet the qualifying conditions for a UK State Pension.'

This wasn't done for me as my N.I. record is blank for the years I have lived here.

Did they make a mistake in not verifying my contributions here? Is there a box I should have ticked somewhere on the HMRC website?

[nomoss]

[quote user="Woodrup"]

Thanks for that link nomoss

I see HMRC say -

'You can also count relevant social security contributions made in EU countries to meet the qualifying conditions for a UK State Pension.'

This wasn't done for me as my N.I. record is blank for the years I have lived here.

Did they make a mistake in not verifying my contributions here? Is there a box I should have ticked somewhere on the HMRC website?[/quote]

It's years since we applied for our UK pensions, but we were both asked for our previous addresses in the UK and details of employment in the EU (in Spain for us).

They don't just count contributions since living outside the UK, they count ALL contributions paid in each country.

These details were used to determine our contribution records in the UK and Spain, and our entitlement to pensions in each country, which we then verified.

We were automatically sent S1 forms, through which the UK pays for our Health care by reimbursing the French system.

When we claimed our Spanish pensions they similarly asked for NI details in the UK.

[idun]

This is how it worked pre brexit, or should have done.

The only way the UK pension could be affected by amounts of time worked in other countries is if the person had their NI contributions below the threshold of 10 years, so if the contributions were less than those 10, and many working years in the EU, then they should pay a limited amount which would be pro rata.

So say one had a working life of 35years in France and five in the UK, the UK pension should pay 35/5 of those years based on the UK pension amount at that time.

In the case of the OP, sounds like they simply  based it on on the number of qualifying years  pro rata. Unless they had made voluntary contributions, that is all they would ever get.

When working in France, top up NI payments were, perhaps still  are, relatively cheap,  not if one isn't working.

Nomoss, if we moved back to France, we would not get an S1, the french pension means that they would be responsible for our health care, AND cotisations due on said pensions.

If we moved to southern Ireland the Uk would not give us an S1, France would, as more years were worked in France than the UK, and we would pay cotisations in France on the french pension.

We had to have a french S1 when we first moved back to the UK and pay cotisations in France too.

AND if you moved back to Spain, then the UK S1 would have to stop and you would be under the spanish system, I believe that that is how it works. ie Spanish pension and residence no S1.

There is a system in place, it just sometimes feels a little complicated.

https://europa.eu/youreurope/citizens/health/when-living-abroad/health-insurance-cover/index_en.htm

It is quite clear under the pensions bit.

[Woodrup]

The French Pension service only told me they were waiting for a reply from HMRC to explain the delay in starting my French Pension, they hadn't asked me for any details, my UK address, my Nat Ins number, nothing.

HMRC may have asked me about EU employment, I can't remember, but I would have told them if they asked.

Anyway, it's looking like I'm getting what's due eventually between the two of them.

Presumably I didn't need the S1 form because I was covered here because I was working?

Do you have a Mutuelle complimentary health cover too? Mine is quite expensive, €57 p.m. now and rising to €85 next year and €106 in 2023.

[nomoss]

[quote user="Woodrup"]

The French Pension service only told me they were waiting for a reply from HMRC to explain the delay in starting my French Pension, they hadn't asked me for any details, my UK address, my Nat Ins number, nothing.

HMRC may have asked me about EU employment, I can't remember, but I would have told them if they asked.

Anyway, it's looking like I'm getting what's due eventually between the two of them.

Presumably I didn't need the S1 form because I was covered here because I was working?

Do you have a Mutuelle complimentary health cover too? Mine is quite expensive, €57 p.m. now and rising to €85 next year and €106 in 2023.

[/quote]

I don't think you are entitled to an S1 from the UK for France, as you are already in the French health system.

We received S1's from the UK, but I don't know how that was decided, as I had made more contributions in Spain, and my wife more in the UK. Maybe nationality is the "tie breaker"

We have a mutuelle, but pay a reduced amount, as we are entitled to the Complémentaire Santé Solidaire (CSS)

This depends on income, to which is added a notional amount for house owners.

Details are HERE

There is a simulator included, which will tell you if you qualify.

Prior to obtaining the CSS we were each paying €98 per month for our mutuelle.

As Idun said, if we were to move back to Spain, which is unlikely, especially after more than 20 years here, we would be covered by the Spanish system, not via S1's, but as pensioners we should have the right of residence there.

[idun]

Yes, the french will want to know how many years you paid in NI contributions. And that is important that they do, as 10 years in France is not enough and the calculation is different if you have not got enough trimestres in.

In France this is important, and the wait, well, it can literally take an age.

You could call Newcastle, usually they are very helpful.Aand get them to send a record for yourself and ask them to also send this info to the french pension people.

As we are of that age, we know lots of people who are retiring. Sometimes, it all goes like clockwork, really easy and paid on time, and others it is like pulling teeth. We were the latter, but that is us, if it can go wrong, it does.

[Woodrup]

Thanks for that link, I didn't know about that.

[Woodrup]

I was warned by a work colleague, and it says on the French Pension site they take 3-6 months to administer new pensions.

In fact I was looking at my UK Nat Ins record on a HMRC web page this week and thought would it be worth printing it and sending it to Caisse Retraite.

I had a Polish girlfriend living with me in England in the 90s and she said UK Govt paperwork is worse than in Russia (she was an English and Russian language teacher). Well, where does that leave the French because I say they are worse than UK !

[Woodrup]

...... These smileys arent working right for me, didn't mean to put one in the title :-/

[suein56]

Woodrup wrote the following post at 24 Apr 2021 8:14:

I was warned by a work colleague, and it says on the French Pension site they take 3-6 months to administer new pensions.

It can, according to hairy stories I have heard from friends, take a lot longer than that .. or it used to.

Hopefully they have speeded up a bit/a lot nowadays.

[idun]

Several years before the french pension was due, we were asked to hand in the NI contributions.

Then as soon as permitted, so months and months before it was due, we applied for the french pension, we were sent endless paperwork, literally it went on and on and on.

Then in early January and the pension should have started at the end of January I called and asked if we had had all the paperwork to fill in. And was told yes.

Late February another lot of paper work arrived and another lot. So I called again and was told that yes, to be filled in.

The complementaire had started paying from the end of January.

Off went all this paperwork, and then the complementaire started writing to us, stating that unless we were in receipt of a state pension then the complementaire would stop.

Panicked, I called and called and called the CRAM, and the complementaire wrote again with a stop date. I think that they gave us another month or so.

I called the CRAM several times and was told in no uncertain terms that they would get round to our dossier and there were lots of other people who were also waiting, but they now had all the paperwork. So I made it perfectly clear what I would do if they did not get our dossier sorted out immediately. No shouting on my part, I was speaking to a Manager. That was the Wednesday or Thursday, the money was in our account on the Friday.  That was in May!

How do they expect people to live.

Friends did exactly as we did, and theirs was paid bang on time.  Another friend had a nightmare getting them to get their NI contributions, as they would not accept the copy they had, it had to comeby post from Newcastle apparently.

[Woodrup]

Well suein56, I started my application in January whhen I stopped work, and found their system incredibly complicated, especially my work history record. Add to that there is no office or face to face option to sort problems within an hour of where I live. Consequently both my state and complimentary pensions departments move the starting date forward incrementally because I haven't jumped through their hoops.

It's a nightmare.

[Woodrup]

I feel your pain idun!

I'm relieved to discover it is not just me.

The French Pension Service really are living in the dark ages, despite their convoluted incomprehensible websites.

I have just lost another 2 hours of my life photocopying and printing stuff to send to them, most of which was already sent by mail and uploaded to their website electronically.

I have just had the letter from the complementaire asking for proof of my state pension entiltlement too. I called the state pension people asking what actual document this is, they said it's available when you reply to our letter of 9th April stating you are starting your pension before age 76.... I replied to that letter the day after! Do it all again.

Yes I thought about sending them my N.I. contributions too, available on my HMRC account page, but didn't as I assumed it would need to come from Newcastle direct. I anticipate this will take the French months to obtain therebye delaying the start of my money well into the future.

Thank god the UK Pension was a simple case of a 10 minute phone call to confirm who I am, no heaps of paperwork going to and fro endlessly!

[NormanH]

I have 3 separate (though each is very small) French pensions, so I had to do this 3 times over.

I found the website and information perfectly simple to follow, but I was helped by the fact that we have an office in town.

[idun]

Yes, the complementaire will ask when you get your CRAM pension, but they actually do know that you are not getting it yet and it is, IMO simply a gee up to get the state pension people to do their stuff.

The complementaire and CRAM have been linked up for years and years and in theory are even more linked up now, which does not help if one is simply stuck.

We had moved back to England when we had to apply, and the amount of paperwork we had to fill in and send back was obscene. And it kept coming and coming.

The only good thing for us was that the complementaire was a bigger amount than the state pension and they started paying it immediately until they realised that the CRAM had not followed suit and that was when they started threatening us with stopping it completely.

My friend was used to dealing with the CRAM as part of their job, and they still ended up waiting months and months and months.

I am so sorry for you and the only thing I can suggest is that you call Newcastle on 00  44  191 218 7777 and ask if they have even requested your NI contributions, you really need this in France, it will affect your pension, as they reduce the state pension by %'s if there is not a full working life. AND see if they can send it the CRAM if you give them the address. Then call the CRAM and ask to speak to a manager and ask what on earth is going on, calm and polite though.  And you could ask how one

Did you know it is illegal in France to get angry with the fonctionnaires?

Good luck, this happens to french people too, and there will be some system in place to complain officially, but they will cover their backsides with Corona excuses at the moment, remember you are not alone, your story simply sounds like that of so many others.

[idun]

 NH was there a good reason why they did not lump all your pensions together?

We had about 6 over the years and then suddenly a letter wrrived with them all on it and their values and Humanis started paying as one payment.

[NormanH]

Perhaps because they are from different "caisses"?

Public  as in in éducation nationale

Private as in a business

Complementaire as in Agirc-Arrco

[NormanH]

Perhaps because they are from different "caisses"?

Public  as in in éducation nationale

Private as in a business

Complementaire as in Agirc-Arrco

No begging letters please. The total is less that 100€ a month[:-))][B]

[Woodrup]

Thanks for that advice idun. I'll give Newcastle a call, good idea.

Thankfully it's only a matter of €150 per month for each pension so I can survive delays, it's just the fact they keep moving the start date forward so I lose €300 every month it is delayed.