Overview. If you live in the UK and another country and both countries tax your income, you're a dual resident. You can claim full or partial relief on UK tax if the 2 countries have a double taxation agreement that allows you to do so.
If you meet the domestic tax residency rules of both countries in the same year, the tie-breaker rules outlined in the UK/France double tax treaty will determine where you pay taxes. These look at where you have a permanent home, where your personal and economic interests are and where you have a habitual abode.
If you are a UK National you can stay in France more than 90 days at a time. It is still possible for UK nationals (like Canadians, Americans & Australians) to live in France for 1 year to 4 years and also apply for permanent French Residency.
Since December 2009, the UK and France have had a double taxation treaty in place which means that you can legally avoid being taxed for the same income in both countries – however you will have to pay tax somewhere.
The current Double Taxation Convention that applies between the UK and France was signed in London in 2008, by the then-UK Chancellor of the Exchequer Alistair Darling, and the then-Finance Minister in the French Government, Christine Lagarde. It replaced the original treaty signed between the two countries in 1968.
There is a double taxation agreement between France and the UK which will not be affected by Brexit (as it has been drafted and signed between the 2 countries outside the EU. The agreement means that you are either taxed in France or the UK on each income/pensions/revenues, etc.
Determining if your tax residence is in France
You have your household in France if you live there most of the time and permanently with your spouse (or civil partner and/or children) or alone. If you do not have a household, the location of your main abode will be established based on your actual presence in France.
In order to avoid double taxation, tax deducted at source in France gives rise to an equivalent tax credit in the country of residence (depending on the tax treaty between France and the country of residence). Helpful tip: Most international taxation treaties make provision for temporary postings.
If you are looking to retire to France from the UK, unless you hold a European passport, you will now need to apply for a Long Stay Visa (which is also called French Residency). Thankfully, the French have made the process quite straightforward.
you have your home or main place of residence in France.
As a general rule, you are a resident of France if you spend more than 183 days a year in France. you are engaged in a professional activity in France, whether salaried or not, unless you can justify that this activity is carried out on an ancillary basis.
Under European Union law, this provision takes the form of an exemption from visas for short stays of 90 days or less in a 180-day period. In this way, British nationals wishing to go to France or another EU Member State for a stay of 90 days or less in a 180-day period do not need a visa.
British arrivals must have an income equivalent to the French minimum wage, which on January 1, 2023, amounted to €1,709 (£1,486) per month, or €20,511 per year. The national minimum wage, or “smic”, in France falls to €16,236 per year after social insurance charges are deducted.
Anyone who meets the requirements for French citizenship by birth has the right to permanent residency. If you have been married to a French national for more than three years, you are eligible to apply for permanent residency right away, even if you have not lived in France during that time.
Yes. Once you get a residence permit for the second country, you are entitled to equal treatment with citizens of that country. Some restrictions as regards access to labour market can be applied for one year.
Can I still buy property in France after Brexit? Yes, you can still buy and own property in France post-Brexit and as a non-EU citizen. If you are planning to stay in your property for longer than 90 days, however, you will need to apply for a long-term visa.
Thanks to your French citizenship, you have the right to enter the UK as a visitor/tourist. You can stay for up to 6 months at a time, but crucially, you cannot make the UK your main home nor undertake any paid work in the UK, except in very limited situations.
You should apply for a long-term visa in your country from the French consulate and you will be granted a “carte de séjour visiteur”. You'll need to prove that you are financially able to live in France – a pension statement will suffice, bank statements showing savings etc.
Should you decide to stay beyond that time, you will apply for a Carte de Séjour Permanent from your local Prefecture. To obtain a VLS you must prove you have an income at least as high as France's minimum working wage (SMIC). As of 2022 this is around €1,250 net (€1,500 gross) per month, or about €2,000 for a couple.
As of the 1st of January 2021, UK citizens will need a Long Stay visa if staying in France or in a French Oversea territory for more than 90 days whatever the purpose of stay (work, studies, ICT, Au Pairing, passport talent, visitor, family reunification, family members of French nationals, etc.).
France has a double taxation agreement with Australia. Other individual and company taxes apply, for detailed information, consult the French taxation authorities. Those considering doing business in France should seek advice from a tax professional specific to their individual circumstances.
The double taxation treaty between France and Australia protects the income and the corporate taxes, besides the royalties, capital gains, and the dividends to be levied only once.
Upon becoming a French resident, all overseas income and investments must be declared on your annual tax return. A pension payment includes a lump-sum pension as well as a monthly, quarterly, or annual pension income. It doesn't mean that all of this income will be taxed or that it will be taxed twice, however.
Dual Residency
For example, an overseas assignment may not be long enough to see you break Australian tax residency but long enough to have you considered a tax resident in your new country of residency - for example, a one year assignment to the UK or Japan.
You may apply for a resident card if you:
Arrived in France as a result of a family reunification procedure; Are joining a non European citizen who has a resident card; Meet the condition of republican integration into French society.
The French taxe foncière is an annual property ownership tax which is payable in October every year. It is payable by the individual who owns the property on the 1st January of the same year and is applicable whether you live in your property or rent it out.