Brits are France's largest anglophone community — and the most under-advised. Your situation sits in a strange middle: no US-style tax shadow follows you, but your financial life was built around wrappers (ISAs, pension freedoms, Premium Bonds) that France simply doesn't recognise, and two systems' worth of rules meet in your kitchen. The good news: every one of those collisions has a known, legal answer — and most of them are cheaper to fix before events than after. Here's the complete map.
What's in this guide
- Your UK pensions in France (and who taxes what)
- The 25% lump sum: the £100,000 decision
- ISAs, Premium Bonds & UK savings: the wrapper problem
- QROPS in 2026: the party's over
- The S1: Britain's parting gift
- National Insurance top-ups: the best deal in retirement
- Inheritance: the 2025 reform changed the game
- Rebuilding in French wrappers
- Your UK assets: keep / review / stop
- FAQ
Your UK pensions in France: who taxes what
The 2008 UK-France treaty draws a clean line — verified on the treaty text itself:
| Pension type | Taxed where? | Notes |
|---|---|---|
| Private pensions (SIPP, workplace schemes) | France (art. 18) | Progressive French scale, 10% pension deduction (capped); your provider can pay gross once French residence is registered with HMRC |
| UK State Pension | France | £241.30/week at the full rate (2026/27) — declared with your French return |
| Government-service pensions (civil service, forces, some NHS/teachers) | UK (art. 19) | Stays taxed in the UK; France counts it for your rate with a credit |
| UK rental income | UK first | Taxed in the UK, declared in France with a treaty credit |
The practical must-do: file the France-UK treaty form so HMRC authorises gross payment of your French-taxable pensions — otherwise you'll chase UK refunds every year while also paying France.
The 25% lump sum: the £100,000 decision 💷
In the UK, taking 25% of your pension tax-free (up to £268,275) is a national sport. In France, that same withdrawal is taxable income — the UK exemption doesn't cross the Channel with you.
France does offer a consolation prize: a 7.5% flat levy on pension capital (computed after a 10% allowance — roughly 6.75% effective). But its conditions are strict and widely misunderstood: the payment must not be split and must settle your pension rights. Taking just the 25% and leaving the rest in drawdown — the standard UK move — generally doesn't qualify, pushing the withdrawal to the progressive scale instead.
The rule of thumb that pays for this entire website: if a lump sum is in your plans, decide its timing relative to your move. Taken while UK-resident: 0% (within the allowance). Taken as a French resident: taxable, with a conditional 7.5% option that your withdrawal pattern may or may not satisfy. On a £200,000 lump sum, getting this sequence right can be worth tens of thousands of pounds. Already in France? Don't touch anything before we've mapped the options — there are still good moves.
ISAs, Premium Bonds & UK savings: the wrapper problem
Here's the pattern for every UK tax wrapper: the account survives the move; its magic doesn't.
- ISAs: France ignores the wrapper — dividends, interest and gains inside become French-taxable (flat 31.4% by default since 2026), and as a non-UK resident you can't add new money. The ISA becomes an ordinary account wearing a costume.
- Premium Bonds: winnings are tax-free in the UK, taxable income in France — and the expected return is poor anyway. Usually first out the door.
- UK savings interest: taxable in France (with treaty mechanics), declared annually.
- The paperwork: every UK account and policy goes on form 3916 with your French return, every year — €1,500 fine per forgotten account. It's a disclosure, not a tax, but it's the #1 filing mistake Brits make here.
The strategy is rarely "sell everything on day one" — it's a planned migration: run down the dead wrappers at a tax-smart pace, and rebuild inside the wrappers France actually rewards (below).
QROPS in 2026: the party's over 🎈
A decade ago, half the expat advisors on the Riviera sold QROPS transfers (often via Malta or Gibraltar, often with generous commissions). The 2024 Budget ended the era: since 30 October 2024, transfers to EEA QROPS lost their exemption from the 25% Overseas Transfer Charge — the charge now applies unless you live in the same country as the scheme. There is no French QROPS. Verdict:
- Thinking of a new QROPS transfer? Almost certainly no. Keep the SIPP in the UK and draw under the treaty — simpler, cheaper, cleaner.
- Already holding a QROPS? The question is how to exit intelligently: jurisdiction, fees (often the real problem), exit penalties, and the French tax treatment of what comes out (the 7.5% capital option has the same strict conditions as above). This is a "documents on the table" analysis with a cross-border specialist — I coordinate it; nobody should rush you.
Sold a QROPS years ago and never quite understood it? You're in very good company.
Bring the statements — we'll decode it together, judgement-free.
The S1: Britain's parting gift 🎁
If you receive the UK State Pension and live in France, the S1 form is quietly one of the best deals in European retirement:
- The UK funds your French state healthcare — you register the S1 and get the same coverage as any French resident (top it up with an inexpensive mutuelle).
- The hidden bonus almost everyone misses: S1 holders are exempt from the 18.6% French social charges (2026 rate) on investment income — you pay only the 7.5% solidarity levy instead. On the income from a €400,000 portfolio, that difference compounds into serious money. Tick boxes 8SH/8SI on the return; keep the S1 as proof.
UK State Pensioner in France without an S1 registered? That's priority one — before any investment conversation.
National Insurance top-ups: the best deal in retirement 📈
You need 35 qualifying years of National Insurance for the full new State Pension (£241.30/week in 2026/27 — about £12,548/year), and at least 10 years for any pension at all. Living in France doesn't stop you from filling the gaps:
- Voluntary contributions from abroad are allowed — and where Class 2 rates apply, a year costs a few hundred pounds for thousands of pounds of lifetime pension. It's routinely the highest-return "investment" in a British retiree's file.
- Check your forecast in two minutes at gov.uk/check-state-pension, then run the maths before the April deadline each year.
- Married? Check both records — the lower-earning spouse's missing years are often the cheapest to fix and the most valuable to complete (10-year minimum for any entitlement).
Inheritance: the 2025 reform changed the game ⚖️
For decades, British expats worried about UK inheritance tax following them forever via "domicile". That world ended on 6 April 2025:
- UK IHT is now residence-based: your worldwide estate is in the UK net only if you were UK-resident in 10 of the last 20 tax years (with a tapered exit tail of 3–10 years). A Brit settled in France for a decade+ largely falls out of worldwide UK IHT.
- ⚠️ Assets physically in the UK — property, bank accounts, ISAs — always stay within UK IHT (40% above the £325,000 nil-rate band). One more argument for the planned migration of UK assets.
- Meanwhile, French inheritance tax applies in full to French residents: children get €100,000 each then progressive rates, and an unmarried partner pays 60%. The rare 1963 France-UK inheritance treaty arbitrates the overlaps.
Translation: the planning centre of gravity has moved to France — assurance vie (€152,500 per beneficiary tax-free), marriage/PACS status, and coordinated wills with a choice of English law for the civil side where useful. The full playbook is in the French inheritance guide — including a calculator to see what your family would pay today.
Rebuilding in French wrappers 🧰
Every euro that leaves a dead UK wrapper deserves a living French one:
| French wrapper | The British translation |
|---|---|
| Assurance vie | Your new ISA-meets-estate-plan: tax-advantaged after 8 years, withdraw any time, and the inheritance clause your family will thank you for. Open it early — the clock starts at opening. |
| Luxembourg contract from €50,000 with OPTIMAVI | The same wrapper with a stronger chassis — and it can hold sterling, so you're never forced to convert GBP on a bad day. Portable if life moves again. |
| PEA | The closest thing to a Stocks & Shares ISA France offers: European equities, tax-efficient after 5 years, open to any French resident. |
| SCPI funds | Buy-to-let income without the buy-to-let phone calls — quarterly rent from ~€5,000, including European funds that are tax-gentle for cross-border lives. |
| French property — incl. bare ownership | Full access, mortgages possible (my broker partners handle UK-income files weekly), new-build at ~2–3% purchase costs — and bare ownership at a 25–40% discount if you don't need income yet. |
Your UK assets: keep / review / stop 🚦
| Asset back home | Verdict as a French resident |
|---|---|
| SIPP / workplace pension | ✅ KEEPDraw under the treaty (France-taxed); gross payment via HMRC form; lump-sum timing = the big decision |
| State Pension & NI record | ✅ KEEP — and top up35 years for £241.30/week; voluntary contributions from France are often the best deal in your file |
| S1 healthcare right | ✅ ACTIVATEUK-funded healthcare + 7.5% instead of 17.2% on investment income |
| ISA | 🔍 REVIEW → planned migrationWrapper dead in France; income/gains taxable; declare on 3916; rebuild in assurance vie/PEA |
| QROPS (existing) | 🔍 REVIEW with a specialistFees, jurisdiction, exit options; new transfers: essentially over since Oct 2024 |
| Premium Bonds | 🛑 Usually liquidateWinnings taxable in France, poor expected return |
| UK property (kept & rented) | 🔍 REVIEWUK taxes the rent (France credits it); stays in UK IHT forever; CGT and currency risk on eventual sale |
| UK bank accounts | ✅ Keep freelyJust declare each one, every year (form 3916) |
Written by Vincent Auvrignon
Independent financial advisor (CGP) in France — CIF, IOBSP, COA, ORIAS n°25004390, member of CNCEF. I spent 12 years abroad myself and work with British clients across France — from Brittany buy-to-lets to Riviera retirements. Every fact on this page traces to an official source (the treaty text, gov.uk, Légifrance). More about working with me →
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The honest, regulatory bit 🤝 — everything on this page is general education, shared in good faith and to the best of my knowledge at the time of writing. It is not personal advice: figures are indicative and change with each tax year, rules evolve, past performance never guarantees future results, and every situation is genuinely different. UK pension transfers and complex UK tax questions must involve appropriately UK-regulated advice — I coordinate, I never improvise. Before any decision, we verify what applies to your case — that's exactly what the free first call is for. I'm a regulated French advisor (CIF — ORIAS n°25004390), and formal recommendations always come in writing, after a signed engagement letter.