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Tax write-off on previous UK rental losses after move to France (Europe)

Tax write-off on previous UK rental losses after move to France (Europe)

Old Aug 11th 2019, 10:18 pm
  #1  
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Default Tax write-off on previous UK rental losses after move to France (Europe)

Hi,

I have accumulated rental losses of ~15k GBP on my UK property whilst living in US over last number of years. I have been filing returns both with HMRC and IRS over this time. I am now in a position to pay down my mortgage so that I would start making a profit on my property. I would be able to write-off those historic losses against future gains on my IRS return. However, I am now planning to relocate from US to Europe, most likely France. Will I still be able somehow to write-off those previous losses against future rental profits while living in France? Perhaps I can file taxes for income in France and separately file a return with HMRC for my UK property income?

I'll have to go to a professional with this eventually, just want to get a base understanding first. Really appreciate and thoughts or guidance.

thanks
Fionn
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Old Aug 12th 2019, 6:25 am
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Default Re: Tax write-off on previous UK rental losses after move to France (Europe)

Originally Posted by Fionn View Post
Hi,

I have accumulated rental losses of ~15k GBP on my UK property whilst living in US over last number of years. I have been filing returns both with HMRC and IRS over this time. I am now in a position to pay down my mortgage so that I would start making a profit on my property. I would be able to write-off those historic losses against future gains on my IRS return. However, I am now planning to relocate from US to Europe, most likely France. Will I still be able somehow to write-off those previous losses against future rental profits while living in France? Perhaps I can file taxes for income in France and separately file a return with HMRC for my UK property income?

I'll have to go to a professional with this eventually, just want to get a base understanding first. Really appreciate and thoughts or guidance.

thanks
Fionn
Hi, and welcome to the France forum!
You have to declare ALL worldwide income in your annual Déclaration des Revenus, and the respective Tax Offices sort it out between them.
If you're considering relocating to France, take a look at the "Read-Me: Moving to France FAQs" above. Can't advise further, as you haven't mentioned your age, status (family, employment), etc...
Don't hesitate to ask other questions (healthcare coverage, etc ....), as the threads in the FAQs may not be 100% up to date, and can't take Post-Brexit into account.
HTH
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Old Aug 13th 2019, 5:47 pm
  #3  
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Default Re: Tax write-off on previous UK rental losses after move to France (Europe)

Hi
Since you have had no responses from either the French forum or MBTUK forum it seems that you are asking a question that is outwith the collective experience of BE.
What you are asking is complex - you are asking for tax interaction between three tax authorities.
I think that you will struggle to find an accountant/ tax adviser who has expertise in all three tax regimes.
I do not know the USA / UK tax arrangements but you can read the dual taxation treaties between the USA / UK - the UK / France and the USA / France.
Under the treaty between the UK and France, rental income in the UK is paid and taxed in the UK and the income and tax paid is declared in your French tax return.
I seem to remember that you can offset losses for the four previous years but I am not up-to-date on these tax issues.
Hope you find the answer to your dilemma.
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Old Aug 14th 2019, 1:44 am
  #4  
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Default Re: Tax write-off on previous UK rental losses after move to France (Europe)

Thank you for your input.

I too suspected this was a little too complex for a short post to an Expat forum. As result, I ended up posting also to the UK Money Saving Expert forum where I got a very informative answer.

Link: https://forums.moneysavingexpert.com....php?t=6036507 (Apologies if I'm breaking forum etiquette by linking to an external forum.)

thanks,
Fionn
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Old Aug 15th 2019, 1:37 pm
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Default Re: Tax write-off on previous UK rental losses after move to France (Europe)

just had a quick read of the other forum. NB if you are keeping your US Green Card then you will have to continue fiiing US taxes. That bit about foreign currency gain for the IRS has been well covered in the US forum on BE. A search will provide results.
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