Taxation France/UK

[connolls]

Hello all,

We have opened up our Chambres D'Hotes this year and registered with the Mairie and as an AE. Bookings going well so far !!

This is our only income at present and our only home so are resident here. We kinda knew it wouldn't keep us afloat all year so will probably have to return to the UK about october time to work over the winter.

We are lucky enough to be able to get temporary work for that period in the UK and have family we can stay with.

We are declaring our earnings in France via the quarterly AE system.

My questions are "What do we do about our earnings in the UK ?"

Is there some way we declare this when we come back to France in the spring ?

Do we inform the UK tax office and they "automatically" inform the French offices as we're classed as resident in France ?

Soooooo many questions sooooo little time.

Thanks for any information.

Kind Regards Mel.

[Will]

In simple terms, the general principle is that money earned in France is taxed in France, money earned in UK is taxed in UK. But your whole worldwide income must be declared in your country of fiscal residence, which in your case looks like it will be France.

Of course, nothing is quite that simple, it all depends on things like your employment status in UK and what arrangements you may have made to establish (or otherwise) where you are tax resident. But the above is your best starting point, if it gets more complicated you probablly need to involve accountants.

Frankly, I would not be too worried about taxation, your health and social security arrangements and contributions are probably of greater concern.

[Sprogster]

You also need to investigate your situation regarding French Cotistation and UK NI liabilities, as that is where the problems can arise I believe for dual residents who work in both countries.

As for tax, my understanding is that UK earnings will be taxable in the UK and declarable in France, with the UK tax paid allowable as a French tax credit under the French/UK DTA.

As an aside, the general opinion seems to be that it is not possible to make a living solely from a Chambres D'Hotes in France and therefore you could find your current need to go back to the UK in winter to work, more of a permanent need than you may like.

[connolls]

Hi,

Thanks for those prompt replies, useful information for us.

We will probably have to "suck it and see" in regards to making a living in France with the Chambres D'Hotes, but suspect that what you're saying will be the case.

Whether we can put up with this scenario for a long period will have to wait to be seen.

But thanks for the replies and if anyone else has any experience of this situation please let us know............especially if its all worked out for you.

Kind Regards Mel.

[AnOther]

I would definitely take serious note of what Will says regarding healthcare. AAUI as French residents to qualify for healthcare in UK you will need a French EHIC, or become UK resident again, and I have no idea of what that, and working in UK, could do to your residential and AE status in France.

Without the AE you will not be entitled to healthcare in France nor will you not have worked long enough in UK to qualify for an E106 so you could find yourselves between a rock and a hard place.

A tricky one, good luck !

[tinabee]

Have a look here - there is a section on "temporarily working in UK and resident in France"

http://www.french-property.com/guides/france/public-services/health/getting-health-cover/living-abroad/

[AnOther]

Not sure that reference is applicable in this case as both will be living in UK plus registering as AE will automatically disqualify you from any E forms you may have otherwise been entitled to.