Return to UK

Old Oct 2nd 2019, 6:27 pm
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Having reached the grande age of 80, and having lived and worked in France for more than 30 years, we now need to consider going back to the UK . The problem is, we don't know where to begin with the numerous admin, financial and tax questions, and we need to find an accountant who has links on both sides, but the big accountancy services are very pricy and if anyone has used such a service or knows an accountant that has links to the UK we would greatly appreciate their help.
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Old Oct 2nd 2019, 8:20 pm
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Default Re: Return to UK

Hello again Cator,
You say that we are returning to the UK.
In the UK, you are taxed as individuals and not as a household. This means that you can position savings etc to be tax efficient if one of you has a greater income than the other.
Because of your overseas income you (or both of you) will be required to complete tax return(s).
I am not sure why you need an accountant who has links on both sides.
I also have overseas income which my accountant declares in the appropriate section of the UK tax return.
As long as you have details of non-UK income and any tax paid then it should be straightforward.
You could of course have more complicated finances in France which may need some sorting out but pension income tax and several other taxes are easily dealt with.
I would think that it would be sensible to move as many of your french assets as possible back to the UK.
If you have complex finances in France then you could use a large accountancy firm to sort out the initial move and once your finances are established in the UK, you could move to a smaller, cheaper firm.
Have a look at the "returning to the UK forum" which deals with many aspects of those who are returning to the UK.
Moving back to the UK
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Old Oct 3rd 2019, 5:25 pm
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Default Re: Return to UK

The UK government has a Returning to the UK guide highlighting – at a broad level – what needs addressing. It may be helpful.
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Old Oct 4th 2019, 9:12 am
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Hi Cyrian, and thanks for your reply. Your advice has been very useful and greatly appreciated.I realise that once in the UK my situation would be relatively simple and it shouldn’t be difficult to fill out any income from France such as my retirement etc. It’s the initial point, when leaving that needs to be cleared up, because at present I'm considered as dual resident having kept my UK house. Because my financial social and professional interests have been in France and where I spend more than 183 days, my tax is paid in France due to the treaty.The real problem is that I have a PEA and an Assurance Vie in France which are not recognised in the UK. So, I need to know if I have to close them, and if so when, i.e. in the year of leaving or the year before. All this depends on the UK rules as well as the French.My UK income from a reduced pension ( which is reported on my French tax form) is pretty small and I do not fill out or pay UK tax, but this could change in the year of departure even though the UK tax give a grace period of 6 months.Thanks also for the tip concerning the forum.
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Old Oct 4th 2019, 4:46 pm
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Default Re: Return to UK

Originally Posted by cator View Post
Hi Cyrian, and thanks for your reply. Your advice has been very useful and greatly appreciated.I realise that once in the UK my situation would be relatively simple and it shouldn’t be difficult to fill out any income from France such as my retirement etc. It’s the initial point, when leaving that needs to be cleared up, because at present I'm considered as dual resident having kept my UK house. Because my financial social and professional interests have been in France and where I spend more than 183 days, my tax is paid in France due to the treaty.The real problem is that I have a PEA and an Assurance Vie in France which are not recognised in the UK. So, I need to know if I have to close them, and if so when, i.e. in the year of leaving or the year before. All this depends on the UK rules as well as the French.My UK income from a reduced pension ( which is reported on my French tax form) is pretty small and I do not fill out or pay UK tax, but this could change in the year of departure even though the UK tax give a grace period of 6 months.Thanks also for the tip concerning the forum.
Regarding an Assurance Vie in France, I recall reading that one cannot transport a French Assurance Vie, unlike a similar Luxemburg plan, the latter although typically more expensive is more flexible. I guess therefore that you would have to close your French plan prior to departure to UK.
I suggest you contact your Assurance Vie agent who would be the best person to decide the best time to close or if you can name one (or more) beneficiaries who should receive up to €152k tax-free on your death, and anything over that amount taxed at (I believe) 20% - assuming the policy was established before age 70. This is what we have done for our next-of-kin and our 2 Assurance Vie. We also arrange a meeting approx every-other year with our agent to discuss any current points and changes which may be required.
DMU may wish to comment further as she's had experience with one or more of these French Assurance plans.
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Old Oct 4th 2019, 6:33 pm
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Hi Tweedpipe,
the info on the Assurance Vie was very useful and it fits in with what I was told by the Credit Lyonnais. They told me that I can transfer it to Luxemburg which has some advantages such as by passing the Loi Sapan which could block any withdrawal in case of emergency but they did not tell me that by doing so, I could transport the assurance vie to the UK. This is good news.. As for the PEA, I intend closing it which in view of the prospects for 2020 it's not a bad idea to go into cash. This only leaves the sale of my apartment which I would do before changing to non-resident and thus avoiding the Cap Gains. I will now get in touch with a UK accountant to assist me with the UK paper work regarding the initial year and making a UK tax return.
Thanks again
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Old Oct 5th 2019, 9:10 am
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Default Re: Return to UK

Ho cator
Your residency does not alter CGT situation.
Under the Tax Treaty you will pay CGT on the gain on your property in France if it is recorded as a 2nd home.
The notaire will deduct any tax due before you receive your money.
If you are UK tax resident you then declare the gain and tax paid on your UK tax return where you may need to pay additional tax.
You do not pay CGT on your primary residence in either country.
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Old Oct 6th 2019, 12:45 pm
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Hello again Cyrian,

My intention is to sell the house whilst I'm still a French resident so no CGT in France. As soon as I sell, I will apply for non resident status in France and I will then be UK rsident but I will no longer have a second home, so no CGT in the UK. That is my understanding for the time being but will get professional advice on it.
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Old Oct 6th 2019, 12:47 pm
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Thanks for info Graham, I looked them up
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Old Oct 7th 2019, 11:03 am
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Default Re: Return to UK

Originally Posted by cator View Post
Hello again Cyrian,

My intention is to sell the house whilst I'm still a French resident so no CGT in France. As soon as I sell, I will apply for non resident status in France and I will then be UK rsident but I will no longer have a second home, so no CGT in the UK. That is my understanding for the time being but will get professional advice on it.
I think you are over thinking this.
If you sell the house whilst a French resident then it doesn't matter a brass farthing what happens after that, your liability won't change retrospectively in the light of what happens after the sale.
By "apply for non resident status in France" I assume you mean, you will inform the fisc that you are no longer resident. Again, you're making it sound far more hassle that it really is. You notify your change of address when you complete your next tax return, they don't want to know about it the minute you leave. Tax matters are dealt with in retrospect not in advance.
Keep things simple, is my motto.
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Old Oct 8th 2019, 4:34 pm
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Default Re: Return to UK

I too am contemplating going back to UK after a long time in France and 9 in Italy. What is really causing me concern though is what will happen to the taxation of French pensions and other revenues after Brexit. Already this year the French government has slapped a controversial 20% tax on all French income of non-residents (here I mean people living outside France) and on top of that there are the high French social "taxes" CSG which will almost certainly increase after Brexit (as we will no longer benefit from the exemption in CSG accorded to EU citizens).

Last edited by nicktonight; Oct 8th 2019 at 4:47 pm.
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Old Oct 9th 2019, 7:51 am
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Default Re: Return to UK

Originally Posted by nicktonight View Post
I too am contemplating going back to UK after a long time in France and 9 in Italy. What is really causing me concern though is what will happen to the taxation of French pensions and other revenues after Brexit. Already this year the French government has slapped a controversial 20% tax on all French income of non-residents (here I mean people living outside France) and on top of that there are the high French social "taxes" CSG which will almost certainly increase after Brexit (as we will no longer benefit from the exemption in CSG accorded to EU citizens).
Could you be more specific?

Re the social charges, AFAIK, the only French source income that non residents pay social charges on is French rental income. Other than that, if you're not covered by the French healthcare/social security system you don't pay CSG-CRDS, and if you don't live in France then you won't be covered.

Re the 20% "tax" increase, are you talking about income tax here? If so, in what circumstances are you anticipating remaining taxable in France as a non resident? As far as pensions go, surely the UK-France DTA cuts both ways, so if you have a French pension and you live in the UK, then unless it is a French government pension (unlikely unless you are a French national, because non French nationals can't be fonctionnaires) it will be taxed in the UK, not in France. Obviously if you have income from business or property in France it's different, but then, tax is always an issue if you have international business interests.

Or am I missing something here?
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Old Oct 9th 2019, 8:18 am
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Thanks Eurotrash for you answer and yes I am a bit/very confused! Concerning the 20% tax I mean the new 20% tax rate that applies to income from French sources (paid to non-residents) up to €27,519 and 30% for any income above this. Not only that but if the UK leaves the EU all "French sourced passive income" (whatever that means) is subject to 17.2% of social surtaxes, which means there is a potential minimum French tax rate of 37.2%! Do you mean that my French pension won't count as French sourced passive income if it is paid into my UK bank account and that tax and CSG will not be deducted first? That would be very good news. These new measures have given rise to lots of controversy in particular for people who live in Belgium or Switzerland and work in France
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Old Oct 9th 2019, 8:55 am
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You may be right, sorry if I gave you false hope.
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Old Oct 25th 2019, 6:59 am
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Originally Posted by EuroTrash View Post
I think you are over thinking this.
If you sell the house whilst a French resident then it doesn't matter a brass farthing what happens after that, your liability won't change retrospectively in the light of what happens after the sale.

By "apply for non resident status in France" I assume you mean, you will inform the fisc that you are no longer resident. Again, you're making it sound far more hassle that it really is. You notify your change of address when you complete your next tax return, they don't want to know about it the minute you leave. Tax matters are dealt with in retrospect not in advance.
Keep things simple, is my motto.


Sorry for the delay in replying but I understood that you have to be French resident for more than the 6 months in the year of departure before you can benefit from no CGT sale in France.
Uk tax starting in April, then return must be after mid October so as to avoid paying UK CGT on sale. That's why you should inform authorities of date of departure after selling the house. I maybe wrong in this, and that was reason for seeking out a tax consultant who knows both sides.
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