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UK employee, French tax?


Pangur

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My husband's company have agreed to let him work remotely in France, which means we can now move over .  However, we now have to get our head around taxes!

Is is possible to remain an employee of a UK company, yet pay taxes in France?  Or, will he have to set up as self-employed in France and sort out his own tax.  Any experiences to share?  I'm sure the company's accountants will help, but they're not going to be too knowledgeable about the French system and we'd like to understand our options.

 

 

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I am in exactly the same boat, except I've been in France for 6 months and have everything set up(or so I hope!!!) Here's a few tips :

1) You can be employed by a UK company and reside in France. You'll pay Frency Tax and social security, and not pay a thing in uk, unless you plan to be in the uk more than 178 days a year. Then it gets complicated.

2) since the French administration have no juridiction over UK companies, you'll be liable for both Employee and Employer contributions. My compay pays me gross and adds the contributions, then I take care of the rest. You'll be what is called 'A Sole representative of a Foreign Company' You are still employed, and NOT self employed.

3) French system is wickedly complicated and confusing. Find an accountant (French) to produce your monthly wage slip(UK one no use in France). It's 3 A4 sheets long!!! I pay somehing like €15 a month for the privilage...money well spent!

4) French employer contributions are much higher than UK ones, so unless your employer is kind enough to make up the difference, then you'll have to make it up yourself.

5) Do NOT bother with UK accountants who claim they have expertise in bth UK and FRANCE, they charge a bomb (£1000) and give you NOTHING. (once bitten, twice shy!)

 

any other questons I can answer, please contact me

Steve

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Thanks so much for the speedy reply Steve, I'm sure we'll be swopping admin frustrations soon .  Just one question at this stage - where did you sort out 'A Sole representative of a Foreign Company' status?  Do we need to register with the Mairie / do through a french accountant once we move there?

 

 

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We actually went to the local URSSAF office first, but I'm sure if we'd gone to the Acountant first she could have arranged all that for us. One word of warning, my wife is French, so it was easy to communicate what we wanted to do, but still got a few blank faces. If your French is not up to that then you're better off finding an accountant who can do it. Where will you be in France, maybe you can have my accountant who now knows what to do.

steve

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Thanks Steve,

We're going to be in Haute Savoie and have some contacts over there so we should be okay.  Good practice for the french in trawling through the URSSAF website anyway.  

It's a relief to know this can be done as makes his company feel much happier about investing in this, and we definitely need to keep them onside!

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As far as the company is concerned, they have nothing to do. all the work in setting things up is from your side. Another point  forgot to mention, is that any expenses incurred for travelling back to the UK for business can be reclaimed against tax and social charges. I've found I don't need to go back that often (Last tie I was in the UK was August, next trip booked for December) ADSL connection is a must though..for me at least!

Can I ask what line of work your husband is in?

Steve

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I'm in the same line of work...everything is working out fine. My employers were a little wary initially and put me on a 6 month probation. 6 months are over, they are very happy with things and I got a raise!

So go for it, you won't regret it!

Steve

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  • 2 weeks later...

Hi Steve,

I am also moving to France and my UK employer has agreed to let me work from there. Now you said earlier that in France you have to pay Employer and Employee social contributions. I was not aware of this. Can you please tell me how much the Employer contributions amounts to? Is it a percentage of your income?

Thx.

 

Christophe.

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In very round figures, employer contributions can amount to some 40% of your salary, and employee contributions of 20-25%, depending on amount. So expect to retain about a third of what you will be paid. Don't forget that you have subsequently to pay income tax - there is no PAYE in France - but at least you are only taxed on what is left after social charges.
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If you travel back to the UK regularly, you can reclaim expenses as your place of work is now France, and travel to UK(or anywhere else) is deemed as expenses. That's assuming you pay them yourself.

You do pay more here, but I find that after all is said and done, and you include cost of living, it's about equal(e.g. car insurance is same here as in uk, in euros, so about a third cheaper, I had private health cover in uk, and my top up insurance here is again 1 third cheaper)!

 And as far as social charges are concerned, you get what you pay for...the health system is second to none. (yes I've had to use it a few times so I know what I'm saying)

Steve

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Thx Steve.

Another question about income tx this time. Some people might think it is a dumb question. My compnay has told me that they will stop paying NI as soon as I move to France. But they say that they will still be paying PAYE tax to the UK - as before. Here I have heard conflicting stories. Some people say that you can ask the UK for your money back and then deal with the French tax system. Other are saying that you offset the amount of income tax the French are asking for against the amount of PAYE you have already paid in the UK. And other people are even saying that you can even ask your company to stop paying PAYE to the UK - meaning you get a special PAYE code.

What's happening in your case?

Christophe.

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I filled in a form before I left the UK...can't remember the what form it was, but you should find it on the IR website, applying to be exempt from tax in the UK. The IR will then contact your employers giving them permission not to deduct paye. At first there was an inital delay, and it seemed I'd have to pay both for a while then get a refund....a few phone calls, and I sorted it out. I am now paid gross (very painful when you see it, and then you have to pay it later) and then take care of things on this side!

I'll try and remember what the form was called!

Steve

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Hello again Steve,

Looks like we're going to have to source our own accountant from the local tax office.  Do you have any details on what this particular tax regime is called  in France / any particular reference number of forms as it will help greatly if we can point them in the right direction rather than being told it doesn't exist. 

Christophe - there are some really helpful documents on the UK Inland Revenue site, which tell you how you can continue paying UK NI for a limited amount of time.  In fact there's loads of stuff on there, but this is what I've just skimmed:

NI38 - Social Security Abroad

CA78A - International Services Employers Pack

and SA29 from DWP's site - Your Social Security insurance, benefits and healthcare rights in the EEA 

(cheers Nicola!)

 

 

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While it is possible to continue paying NI in the UK (up to a year), that scheme is supposed to be for employees seconded to a French office for a set time. I don't know if you have to prove that that is the case. As to the forms/scheme etc etc, it's all too complicated for me, and  have got an accountant taking care of everything. Just to demonstrate how complicated it is, my monthly payslip is 4 A4 sheets long!!!

Steve

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Thank you all for your help. It is much clearer now. I filled in a P85 more than a month ago but I am told it has not been processed yet. I got in touch with DWP a while back and someone was supposed to get back to me but I am still waiting - I need a form from them stating how much NI and pension contributions I have paid in the past I think.

I guess a good accountant in france is mandatory to sort all this mess. They're going to make a fortune! This is when you wish Europe was one big state!

Thanks again everybody.

Christophe.

 

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Christophe,

I was pleasantly surprised with how much my accountant charges...when you see the pay slip you know it's money well spent. As for one Europe....bulls..t is all I can say. Apart from freedom of movement, everything else in our move was difficult and not made any easier by us all being in the EU. I don't know if you were to move from say Germany to France if things would be any easier. (Well you wouldn't have exchange worries at least!)

Steve

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We are moving to France this month and my husband will continue to receive income in the form of dividends from his directorship/shareholding in a UK based trading company. The dividend payments will be subject to advanced Corporation Tax but how will this be treated when the money is transferred into our French bank account.

Regards

Jackie

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My UK bank told me you can continue to pay into a UK pension fund for 5 years after emigrating, I don't yet know the situation on tax relief, I guess that depends

> Europe....bulls..t is all I can say. Apart from freedom of movement, everything else in our move was difficult and not made any easier by us all being in

You didn't need a work visa, try doing the same to the US and see how you get on :-)

Actually any kind of social change/income tax harmonization has been anathema to the UK for several years, and the tax framework that affects you predates the UK entry to the EU - 1969 (http://www.britishembassy.gov.uk/servlet/Front?pagename=OpenMarket/Xcelerate/ShowPage&c=Page&cid=1065717333331)

 

 

 

 

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This is a quetion for Steve. Its me again.

I am a bit alarmed - not just bit but quite a lot - by what Will said earlier. Employer social contributions amount to about 40% of your wage. And then on top of Employee contributions amounts to 20-25%. And then you have to sort out your income tax!!!! You have nothing left!

So Steve is that really what you're losing out every month from your pay packet? Could you tell me - as a percentage figure - how much take home pay you're left with after deducting employer/employe charges and income tax?

Thx.

Christophe.

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Christophe,

I'm paid gross plus what my employer would have paid in NI charges in the UK (12% I think) from that figure I pay around 43% in total per month on social charges(both employer and employee) Tax, I have worked out will be about 1 month's wage for a year(depends on whether you're married or not and have kids)....so yes it's expensive!!

Steve

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