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delaring earnings from UK


chocccie

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We live in France, but my husband has been working in the UK for some months.  He pays tax on a PAYE basis in the UK.

Can anybody give me any advice as to how he declares it here in France - on a tax return obviously, but what is the score as to any further tax? 

Will he be taxed any extra (ie, if the amount of tax he's paid in the UK doesn't equal what he would have paid if he worked and was paid in France).

If anybody has had any experience of this situation, I'd be grateful for any comments from them.

Many thanks

 

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Choccie

if you're resident in France but have income from an employment in the UK, in principle it is taxable in both countries. You have to pay the UK tax (hard to avoid this really, but it's worth making sure you do a tax return and don't just rely on the PAYE deductions being right). Then the tax you've paid in the UK is available as a credit against the tax due on the income in France. You have to put the income on your French tax return gross (ie the amount before the PAYE tax was taken off).

It's a bit fiddly as your UK tax is paid for a UK tax year, to 5th April, and you'll have to time-apportion the year's tax to get the amount that corresponds to the calendar year's income you put on the French return. You could instead just use the figures from the payslips for the calendar year (January to December), but they won't be quite right if you get a refund of tax when you send in your tax return. Or have to pay more, of course.

If he only has relatively small UK employment earnings, it is quite likely that there will be extra tax to pay in France, even after the credit for the UK tax, though this mostly depends on how much extra income you might earn in France.

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Arucaria has summed it up quite well but I think has made it sound a lot more complicated that it is. What you describe is almost exactly my own situation so I do speak from personal experience.

First of all forget any comparison between the amount of tax your OH is paying in UK and what he might if doing the same job in France the two are utterly unconnected and irrelevent. Out of interest though, unless his salary were very substantial, IF he were able to pay his tax in France he would almost certainly end up paying less than UK. Also I think it very unlikely that he would be liabel for any tax in France however small his salary. The personal allowance system is far more generous and benefits low income families. You can get a flavour of it HERE, but enough of that.

Unless your OH already does fill one in there really is no need to voluntarily submit a UK self assesment form. True you cannot rely 100% on PAYE codes but unless he suspects his is wrong, and in a substantial way (in which case he should do something about it), then figures taken from pay slips will be perfectly acceptable for the French tax forms.

When we submitted out first forms in May 2008 we went to the Impots for advice and a helpful lady there not only filled the form in for us but also made photocopies and told me to just do it exactly the same next time, couldn't have been easier. She put down what I worked out I had received gross since arriving in August 2007 and the tax paid, attached the copies of my payslips for that period and were rewarded in due course with a tax bill of €0.

This year when the form arrived I was surprised to find that it already had a gross figure hand written in which was within a smidgen of what we had worked out so I altered it to that and did the rest as per last year. I must admit that I don't know where that figure came from but I'm assuming it must have been HMRC because I can't think who else would have it !

This is where the wheels nearly came off for me. Mindful of the perennial disagreement on what exchange rate to use I decided to have a quick word with somebody at the Impots which turned out to be a big mistake because she threw a complete spanner in the works however rather than repeat it over may I refer you to THIS thread where the tale unfolded.

The bottom line was though that I decided to just submit the form as it was, exactly as in the previous year, and bingo, another €0 bill.

No prizes for guessing what I'll be doing in 2010 [:D]

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Arucaria has summed it up quite well but I think has made it sound a lot more complicated that it is. What you describe is almost exactly my own situation so I do speak from personal experience.

First of all forget any comparison between the amount of tax your OH is paying in UK and what he might if earning the same in France the two are utterly unconnected and irrelevent. Out of interest though, unless his salary were very substantial, IF he were able to pay his tax in France he would almost certainly end up paying less than UK. Also I think it very unlikely that he would be liabel for any tax in France however small his salary. The personal allowance system is far more generous and benefits low income families. You can get a flavour of it HERE, but enough of that.

Unless your OH already does fill one in there really is no need to voluntarily submit a UK self assesment form. True you cannot rely 100% on PAYE codes but unless he suspects his is wrong, and in a substantial way (in which case he should do something about it), then figures taken from pay slips will be perfectly acceptable for the French tax forms.

When we submitted our first forms in May 2008 we went to the Impots for advice and a helpful lady there not only filled the form in for us but also made photocopies and told me to just do it exactly the same next time, couldn't have been easier. She put down what I worked out I had received gross since arriving in August 2007 and the tax paid, attached the copies of my payslips for that period and were rewarded in due course with a tax bill of €0.

This year when the form arrived I was surprised to find that it already had a gross figure hand written in which was within a smidgen of what we had worked out so I altered it to that and did the rest as per last year. I must admit that I don't know where that figure came from but I'm assuming it must have been HMRC because I can't think who else would have it !

This is where the wheels nearly came off for me. Mindful of the perennial disagreement on what exchange rate to use I decided to have a quick word with somebody at the Impots which turned out to be a big mistake because she threw a complete spanner in the works however rather than repeat it over may I refer you to THIS thread where the tale unfolded.

The bottom line was though that I decided to just submit the form as it was, exactly as in the previous year, and bingo, another €0 bill.

No prizes for guessing what I'll be doing in 2010 [:D]

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[quote user="chocccie"]We live in France, but my husband has been working in the UK for some months.  He pays tax on a PAYE basis in the UK.

Can anybody give me any advice as to how he declares it here in France - on a tax return obviously, but what is the score as to any further tax? 

Will he be taxed any extra (ie, if the amount of tax he's paid in the UK doesn't equal what he would have paid if he worked and was paid in France).

If anybody has had any experience of this situation, I'd be grateful for any comments from them.

Many thanks

 
[/quote]

Your husband's UK income is not taxable in France and is only taken into account for calculating the marginal tax rate on any other income which is taxed here.  There are no tax credits involved nor is there any 'equal what he would have paid in France' scenario. 

As far as declaring the UK income is concerned, he completes tax form 2047 section VII Revenus Exonérés pris en compte pour le Calcul du Taux Effectif with his gross earnings, then deducts the UK tax paid, then transfers the net total to box TI on tax form 2042.

 

 

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[quote user="Sunday Driver"]

[quote user="chocccie"]We live in France, but my husband has been working in the UK for some months.  He pays tax on a PAYE basis in the UK.

Can anybody give me any advice as to how he declares it here in France - on a tax return obviously, but what is the score as to any further tax? 

Will he be taxed any extra (ie, if the amount of tax he's paid in the UK doesn't equal what he would have paid if he worked and was paid in France).

If anybody has had any experience of this situation, I'd be grateful for any comments from them.

Many thanks

 

[/quote]

Your husband's UK income is not taxable in France and is only taken into account for calculating the marginal tax rate on any other income which is taxed here.  There are no tax credits involved nor is there any 'equal what he would have paid in France' scenario. 

As far as declaring the UK income is concerned, he completes tax form 2047 section VII Revenus Exonérés pris en compte pour le Calcul du Taux Effectif with his gross earnings, then deducts the UK tax paid, then transfers the net total to box TI on tax form 2042.

 

 

[/quote]

Hi,

     As SD has said, and the reference is the France/UK double taxation treaty Part IV , Article 15," Dependent personal services", Para (1) and (2). 

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