Social Contributions

[Will]

Can I just add something from my own experience?

Tax and cotisations/social contributions are handled by totally different agencies in both Britain and France. Tax offices (and tax advisers) will tell you about tax,, but cannot advise on cotisations.

Where you pay tax is basically determined by where you are resident. If you meet residence qualifications for more than one country, or if you have liabilities arising solely in a country where you are not resident, then where you pay tax on any particular income or gain is determined by whatever double taxation agreements may be in force.

There are no equivalent agreements covering where you should pay social security. In most cases, where you pay your tax will be the same place where you pay social security charges, but there are plenty of exceptions. So each case would be considered individually. The answer I received from the DSS was that they would, in the first instance, consider where you spend most time. If you spent most of your time in Britain, then you would pay NI. If you spent most of your time in France, then you would be expected to join the French system. It's not as simple as a '183 day rule'.

If, however, you spend time in Britain, France and Germany, but most of the time in Germany, you would have to make your arrangements in Germany. That would mean taking out a German health insurance scheme (which for most people means, in effect, private insurance), and this would include travel insurance giving you access to the British, French and many other health systems. So the nature of the health and social security systems in each country plays a big part in how you pay, even when looking at different European countries.

I can see why people find these questions so complicated. The best thing is to ask a good accountant with knowledge of social security issues as well as tax about your particular situation. Most of the so-called expat tax advisers do, unfortunately, have little knowledge of, and no professional expertise in, social security matters (other than how they may directly affect non-working people).