Frontier Worker / Cross-Border Working Query
Oct 21st 2020, 2:05 pm
#1
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Joined: Oct 2020
Posts: 1
Frontier Worker / Cross-Border Working Query
Hi everyone,
I am in the process of establishing my residency in Lille, but I'm in an unusual situation because I intend to remain working in London during the week, only returning to Lille on weekends. The term for this in EU-speak is "frontier worker" or "cross-border worker", and there are special rules and concessions relating to it. Unfortunately, that also makes it rather complicated! (As does Covid-19...)
As I understand it, a frontier worker lives in one EU country (or, prior to 31 December 2020, the UK) and works in another, returning to the home country on a weekly or daily basis. Such persons are subject to both countries' laws, but end up paying tax (and charges for social benefits) in the country where they work, whilst being eligible to use the public and social services in the country where they live. This is a bog-standard EU scheme which applies to thousands of EU citizens already, so it has nothing particularly to do with Brexit, but the UK's leaving the EU may affect how it works after 31 December 2020. The Withdrawal Agreement treaty effectively enshrined UK citizens' existing EU-related rights in aspic--so long as such rights have been exercised prior to 31 December 2020.
From my research I believe I need to:
1. Move (physically) to France before 31 December 2020 (and obtain documentary proof, e.g., rental contract, utility bills, bank statements)
2. Apply for an S1 certificate from the UK (which is to be presented to the French healthcare system upon enrollment)
3. Enroll in the French healthcare system
4. Register on the new WARP website in France (before 30 June 2021)
5. Enjoy (weekend) life in France!
I am currently at step 1, having arranged a flat for which I now pay the utilities, and I am applying for a bank account with HSBC France. I'm not sure about the best way to accomplish the second step, and there is precious little information out there which I can find. I believe I have to telephone HMRC before they will allow me to apply for an S1, but I don't know what information/documentation I will have to provide them in support of this. An S1 certificate means that the UK agrees to pay for my lifetime (?) social benefits in France, which could explain why they're not making it especially easy to obtain!
I do know that the S1 will only be posted to a foreign address, so that implies that I can only request it after I have physically moved home to France. I'm a cautious person, however, so I'd like to know that I am entitled to (and likely to receive) an S1 before I incur any more expenses related to moving home. Are there any experts in this sort of thing who could help? Cheers.
I am in the process of establishing my residency in Lille, but I'm in an unusual situation because I intend to remain working in London during the week, only returning to Lille on weekends. The term for this in EU-speak is "frontier worker" or "cross-border worker", and there are special rules and concessions relating to it. Unfortunately, that also makes it rather complicated! (As does Covid-19...)
As I understand it, a frontier worker lives in one EU country (or, prior to 31 December 2020, the UK) and works in another, returning to the home country on a weekly or daily basis. Such persons are subject to both countries' laws, but end up paying tax (and charges for social benefits) in the country where they work, whilst being eligible to use the public and social services in the country where they live. This is a bog-standard EU scheme which applies to thousands of EU citizens already, so it has nothing particularly to do with Brexit, but the UK's leaving the EU may affect how it works after 31 December 2020. The Withdrawal Agreement treaty effectively enshrined UK citizens' existing EU-related rights in aspic--so long as such rights have been exercised prior to 31 December 2020.
From my research I believe I need to:
1. Move (physically) to France before 31 December 2020 (and obtain documentary proof, e.g., rental contract, utility bills, bank statements)
2. Apply for an S1 certificate from the UK (which is to be presented to the French healthcare system upon enrollment)
3. Enroll in the French healthcare system
4. Register on the new WARP website in France (before 30 June 2021)
5. Enjoy (weekend) life in France!
I am currently at step 1, having arranged a flat for which I now pay the utilities, and I am applying for a bank account with HSBC France. I'm not sure about the best way to accomplish the second step, and there is precious little information out there which I can find. I believe I have to telephone HMRC before they will allow me to apply for an S1, but I don't know what information/documentation I will have to provide them in support of this. An S1 certificate means that the UK agrees to pay for my lifetime (?) social benefits in France, which could explain why they're not making it especially easy to obtain!
I do know that the S1 will only be posted to a foreign address, so that implies that I can only request it after I have physically moved home to France. I'm a cautious person, however, so I'd like to know that I am entitled to (and likely to receive) an S1 before I incur any more expenses related to moving home. Are there any experts in this sort of thing who could help? Cheers.
Oct 21st 2020, 2:34 pm
#2
Lost in BE Cyberspace
Joined: Jan 2012
Location: Dépt 61
Posts: 5,254
Re: Frontier Worker / Cross-Border Working Query
You have it spot on I think.
Just one point on the tax - if you are resident in France you're legally obliged to declare your worldwide income to the French taxman. If you carry out your work in the UK then your salary will be taxable by HMRC, and the dual tax treaty will be applied so you won't be taxed double on any of your income but there may be some adjustments, depending on your exact circumstances. For instance I suspect you may be liable to pay CGS/CRDS in France (if you haven't looked into this, google will be your friend but here is somewhere to start https://www.french-property.com/guid...l-welfare-levy ).
And another tiny point, I am not sure if this is guaranteed "for life" in that I think it's specific to your current situation. If you change jobs in the UK after transition I'm not sure you would get another S1.
Re the S1, yes you need to apply to HMRC/DWP, confirmed here https://europa.eu/youreurope/citizen...s/index_en.htm. I did get one many many years ago but I can't remember much about the process and it may be different now, but as I recall there was a form to fill in with details of working pattern ie how many working hours you spend in the UK and France during the year, If you work full time in the UK and you don't work at all in France I can't see there would be a problem. Suggest you get on the phone asap because as I recall it took them a long time to process my application.
Just one point on the tax - if you are resident in France you're legally obliged to declare your worldwide income to the French taxman. If you carry out your work in the UK then your salary will be taxable by HMRC, and the dual tax treaty will be applied so you won't be taxed double on any of your income but there may be some adjustments, depending on your exact circumstances. For instance I suspect you may be liable to pay CGS/CRDS in France (if you haven't looked into this, google will be your friend but here is somewhere to start https://www.french-property.com/guid...l-welfare-levy ).
And another tiny point, I am not sure if this is guaranteed "for life" in that I think it's specific to your current situation. If you change jobs in the UK after transition I'm not sure you would get another S1.
Re the S1, yes you need to apply to HMRC/DWP, confirmed here https://europa.eu/youreurope/citizen...s/index_en.htm. I did get one many many years ago but I can't remember much about the process and it may be different now, but as I recall there was a form to fill in with details of working pattern ie how many working hours you spend in the UK and France during the year, If you work full time in the UK and you don't work at all in France I can't see there would be a problem. Suggest you get on the phone asap because as I recall it took them a long time to process my application.
