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PENSION

Reader Question: How long do I have to work to qualify for a French pension?

If you have worked both in France and in another country, you might be curious at what point you become eligible for a French pension. Here is what you need to know.

Reader Question: How long do I have to work to qualify for a French pension?
Letters form the word "retirement" around numbers in relation to the pension reform sought out by French government (Photo by Lionel BONAVENTURE / AFP)

Many foreigners living in France have had blended careers – meaning they have worked in both France and at least one other country. This can make it complicated for navigating where you fit into the French state pension system, as well as the one for your home country. 

The key question most foreigners who have worked in France tend to ask is “How long do I have to work to qualify for a French state pension?” It is difficult to find a direct answer to this question online, and many websites indicate a minimum of ten to 15 years. 

Ask the experts: What foreigners living in France need to know about French pensions

In reality, the answer is that you need a minimum of just one trimestre (quarter) of working and paying taxes in France to qualify for a French pension.

The catch is that French pensions are based on contributions, so although you are eligible after just one trimestre, your pension will be pretty small. The below example is for someone who has worked in France for one year – their French pension is the princely sum of €4 a month.

This simulation is based on a person retiring at the (current) legal age of 62, or the maximum age of 67.

In an interview with The Local, French pensioners expert Denis Guertault, who works for the organisation France Retraite, explained that after one quarter of working in France (on a French contract), you will be entered into the state pension system – however, your pension is based on contributions, so although you will be entitled to a pension, it may not be very large.

You can find out what pension you are currently eligible for by using the French government pension calculator website info-retraite.fr

With the passing of the pension reform (after months of strikes and protests) the info-retraite website has now been updated to include the new retirement ages – gradually increasing from 62 to 64 between September 2023 and 2030, with a maximum age of 67 for people who do not have a ‘complete’ career (ie people who had career breaks such as stay-at-home mums, people who started work late after prolonged study or people who worked in a non-EU country).

READ MORE: EXPLAINED: The website to help you calculate your French pension

“France works on a system of droit acquis (acquired rights),” the Guertault explained. Essentially, this means that the system is set up to be ‘pay-as-you-go.’

If you are an employee in France you will already be paying into your pension, since this is compulsory. If you take a look at your French payslip, among the deductions for social charges is the ‘retraites‘ section and this shows your pension contributions. These can be quite high – OECD data shows that the average French worker pays 11 percent of their monthly (gross) salary into their pension. 

For self-employed workers, this is part of the deductions set up via URSSAF. 

READ MORE: How to understand your French payslip

There are, of course, some exceptions, and the primary one is for people who have ‘posted worker’ status.

The Local also spoke with Tax Partner Jonathan Hadida, who works for Hadida Tax Advisors, a company specialised in tax consulting and helping Americans living in France to be tax compliant in both countries.

“This does not apply to people on a ‘seconded’ contract, who can request to stay on US social security for the first five years,” Hadida said,

“Generally what happens in a lot of these cases, is that the worker would continue to be paid by the US company, though different companies have different rules,” Hadida explained. The tax expert clarified that this is only available for the first five years for American posted workers, however. After five years, they will begin contributing to the French pension system.

When am I eligible for a full French pension?

Prior to September 2023, the minimum retirement age is 62, and to qualify for a full pension (at the maximum rate of 50 percent), you must have worked a certain number of trimestres (quarters). The exact number of trimestres depends on the year you were born. Those born between 1961 and 1963 need 168 trimestres, or 42 years. Those born in 1973 or after currently need 172 trimestres, or 43 years.

The minimum retirement age will gradually increase from September 2023 until 2030, when it will reach 64.

Importantly for foreigners who might be lacking a ‘full’ career in France, the maximum age remains at 67.

Periods of unemployment, maternity leave or absence because of long-term illness or accidents at work are taken into account and these credits count towards determining your total number of trimestres.

For the average French worker, the calculation for how much one’s pension will come out to be will be based on average annual income for the best 25 years of your earning career, and the amount to which you are entitled is based on how long you have paid into the system.

However, for foreigners who have worked in both France and another country, the calculation for the total amount of your pension will depend on whether the other country you worked in is part of the EU/EEA or whether it has an existing social security agreement with France. 

READ MORE: Pensions: What should I expect if I worked in both France and a non-EU country?

If the other country you worked in does have an agreement with France (or is part of the EU), then the two will work together to determine how much your pension will be from France, and how much it will be from the other country. This formula will depend on the nature of the social security agreement between the two nations, however.

Once calculated, you will receive one sum from France, and another from the other country you worked in. Keep in mind, that this may mean you will need access to a bank account in the other country to receive your pension payout.

READ MORE: Ask the Expert: How Brexit has changed the rules on pensions, investments and bank accounts for Brits in France

If you have been in France for more than 10 years, you may also be eligible for ‘top up benefits’ when you retire, if your total pension is below a certain amount. 

This article is a general view of the pension system and does not constitute individual financial advice. If you are are unsure about your pension rights, seek independent financial advice.

Member comments

  1. Can anybody tell me how to get an answer from the CARSAT in Rouen that, apparently, deals with the dossiers for all French pensions paid to non-French nationals. I am receiving only approximately 30% of my predicted (by the French) pension and never get a reply, even to registered letters, asking for why the amount varies so considerably from their previous calculation
    I was self-employed, and paying tax, here for 20 years, although latterly discovered that I was credited with only one trimestre, for many years, for the ‘cotisations’ that I thought were going towards my pension, but this was taken into account in their original computation.
    I enjoy living in France, but hate the stonewalling administration as much as the French do themselves!

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LIVING IN FRANCE

Are Canadian pensions taxed in France?

If you are considering retiring to France, you might be wondering whether you will still be able to access your Canadian pension and if it will be subject to French taxes. Here is what you need to know.

Are Canadian pensions taxed in France?

Before going any further, it is worth noting that this article is meant to give an overview of the pensions situation for people with Canadian pensions. It does not replace professional financial advice, and Canadians looking to retire in France should still seek out expert financial assistance as needed.

The first step is to determine whether or not you are a tax resident in France (you can look through our guide). All tax residents must fill out a yearly tax declaration, and they must report all global income, even if it is not subject to tax in France. 

You should also consider if you have a pension from another country besides Canada, as different rules may apply based on that country’s bilateral tax treaty with France. Here is the situation for British, American, and Australian pensions, and here is an overview of the system.

Where is my pension taxed?

In Canada, the pensions system includes multiple tiers of public and private schemes, but luckily the double tax treaty between Canada and France is explicit about where pensions are taxed.

The Local spoke with Isaac Barchichat, a registered CPA in France, Canada and the USA to understand the situation for Canadians in France. He is a managing partner at Monceau CPA, an international accounting firm based in Paris with offices in the US and Canada.

He told The Local: “Tax treaties usually follow the OECD model, which means that Article 18 is usually focused on pensions.

“Article 18 for the Canada-France treaty is very similar to the USA-France treaty. This means that pensions are taxed in the country that they are issued in,” he said.

As a result, any Canada-based pension – whether that is the Old Age Security plan, the CPP (Canada Pension Plan) or QPP (Quebec Pension Plan), or a private personal or employer plan (such as Registered Retirement Savings Plans, or RRSPs) – would be taxed in Canada, not France.  

Barchichat explained that Canadians in France should still declare their pension income in France. Like Americans, they will receive a tax credit from France attesting that they have already paid tax in Canada on their pension.

“People should still maintain proof that the pension was already subject to tax, in case of an audit,” he added.

Barchichat also recommended that Canadians resident in France can make use of the ‘mention expresse’ section in their French tax declaration.

“Sometimes French local tax authorities fail to assess foreign income properly. Using the ‘mention expresse’ allows you to specify to French tax authorities Article 18 from the tax treaty to ensure that they process your documents properly,” he advised.

All of this being said, Canadians should beware that their pension income could still count towards your total household income in France, even though it is not taxed here. As a result, it could end up pushing you into a higher tax bracket.

What about social charges?

In addition to taxes (impôts), France also requires people to pay social charges (prélèvements sociaux) on income. However, only specific types of income can be considered for social charges, such as the CSM charge (PUMa) for healthcare. 

The general rule is that pensioners and their spouses do not have to pay the CSM charge, but France specifically exempts people who have a pension from France, the EU, the EEA and the UK (people with S1 forms), as well as their non-working spouses.

There is some debate over whether American and Canadian private pensions ought to be treated as a pension (and therefore exempt from CSM) or as investment income (which can attract CSM charges). 

When it comes to Americans, tax expert Jonathan Hadida from HadTax told The Local: “Under the principle of equality amongst taxpayers, URSAAF has treated most US pensions/IRA distributions/401(k) distributions akin to a French/Swiss/European pension and have therefore exempted Americans with pension income.”

“I have called URSSAF, and I was told by the representative that they should be paying for PUMa. But in practice, I have not seen many American pensioners charged for it.”

It is likely that similar standards are applied to Canadians. 

Barchichat, who is licenced in both the US and Canada, said that in his opinion neither American nor Canadian pensioners should be charged for prélèvements sociaux

“If this happens, it is a mistake by tax authorities”, he added. You can learn more about contesting a CSM charge here.

READ MORE: Cotisations: Why you might get an unexpected French health bill

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