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

For people who have worked both in France and in another non-EU country, it can be challenging to decipher what to expect from your pension.

Published: 23 January 2023 14:25 CET

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

(Photo by JOEL SAGET / AFP)

For those who move to France when they are of working age, it’s common to have worked – and contributed to a pension – in several countries. So what happens to combining all those pensions when you come to retire?

The short answer is that periods of employment outside France can be combined with years worked in France to boost or qualify for the French state pension – but it depends on which country you have worked in, whether that country is in the EU/EEA or whether that country has a social security agreement with France.

The EU and EEA countries, and Switzerland have social security coordination which means that pensions can be easily combined.

For those who worked in France and another non-EU/EEA country (eg the USA, Australia or Canada) – the pension calculation is a bit different.

For Brits it depends on when you arrived – those who lived in France before December 31st 2020 (ie those covered by the Withdrawal Agreement) benefit from the same arrangements as EU/EEA countries. Those who arrived after that date fall under the general rules for non-EU countries.

The key is whether the countries you worked in – listed here – also have social security agreements with France that will allow you to combine work periods.

A calculation will be done between the two countries to determine the amount of the French pension you qualify for and the amount of the pension you qualify for from your home country. Then, you will receive these payments separately.

A few countries – listed here – have agreements with France for self-employed workers.

The situation for Americans

Americans living and working in France benefit from the Franco-American Social Security Agreement (SSA). Essentially, this allows Americans who have worked in France to have their pension calculated on a pro rata basis. The agreement specifies that this calculation will be done by multiplying the theoretical amount by the ratio of the periods of coverage under French laws to the total periods in both countries.

Take the example that France’s state agency Assurance Rétraite wrote for “Michael”, born in 1955, who worked in both the US and France to demonstrate how the SSA is put into action.

To retire by French standards, Michael would need 166 quarters to have a full rate. If he has contributed 150 trimestres in France, and 18 in the United States, that means that once he has reached the age of 62 (Note: This reference is to France’s previous minimum retirement age, it will progressively rise to 64 starting September 2023), he can apply for his French pension (as he has a total of 168 trimestres worked between the two countries).

The calculation would be as follows:

Screenshot by the Local from AssuranceRetraite.FR

In English, the formula to calculate the amount of Michael’s French pension would be: Michael’s average annual salary X The full pension rate of 50 percent X 150 (quarters contributed in France) / 166 (Total quarters worked).

The reason the calculation uses 166 instead of 168 quarters is that the Franco-American agreement states that to “avoid an excessive pro rata reduction for workers with many years of coverage under the US and French systems, the denominator of the ratio is limited to the number of quarters of coverage required for a full old-age pension under French laws.”

Keep in mind that the number of quarters referenced for a minimum is also reflective of the previous pension standards in France. For anyone born after 1973, the minimum number of quarters in France is set to 172.

Essentially, the agreement allows you to combine years of work in France and the United States, which can count toward your American retirement too.

According to Tax Partner, Jonathan Hadida, who works for Hadida Tax Advisors, a company that specialises in tax consulting and helping Americans living in France to be tax compliant in both countries, Americans looking for assistance with their social security should contact the US Embassy in Dublin, which has a dedicated team to assist with social security questions for Americans abroad.

For Americans looking for more information about saving money and investing while in France, as well as the rules for continuing to access private pension plans, such as a 401K or IRA, you can learn more HERE.

The situation for UK nationals

For Brits who have moved to France post-Brexit, as of 2023, it was still not clear whether an updated social security agreement between the two countries had been put into place.

Those who moved prior to Brexit – as mentioned above – continue to have their pension contributions made in France calculated in the same way that EU/EEA countries have theirs calculated. You can learn more about this HERE.

Keep in mind that you may need a bank account in the United Kingdom to access your UK pension. This has been an issue for some Brits living in France.

The situation for Australians

If you are Australian, you should beware the ‘pensions trap’ resulting from the lack of an international social security agreement.

The lack of a bilateral social security agreement has made it so that many Australians of retirement age who live in France cannot claim an Australian old- age pension, even if they have spent their lives working and paying taxes in Australia. You can find the full details here.

A final key point is for foreigners who receive a state pension from their home country, you may need to have access to a bank account in that country to collect the funds.

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.

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9 things Brits need to know about moving to France since Brexit

Brits who want to move to France now face a radically different process from those who took advantage of EU freedom of movement to make the move before Brexit.

It’s a more complicated process – but it’s still possible and 8,700 UK nationals moved to France in 2023.

Here are some of the big things you need to know before making the move.

1 Visa

The biggest post-Brexit change is that Brits moving to France now require a visa (unless they have dual nationality with an EU country).

The visa must be applied for first, and only when it is granted can you make the move – you cannot come to France and then apply for residency (unless you are covered by the Withdrawal Agreement, more on that below).

There are various different types of visas depending on what you intend to do in France – work, study, retire etc – and many of them contain conditions eg people on a ‘visitor’ visa are not permitted to work in France.

It makes things less flexible as it’s harder to change your plans once you have arrived. It also means that it’s harder to have a ‘half and half’ lifestyle – eg retire from your day job and move to France to run a gîte or B&B.

Explained: What type of French visa do you need

The best visa type is undoubtedly the ‘Talent Passport’, so it’s worth checking whether you fit any of the criteria for this visa type.

2 Residency card

Once you have your visa and have moved to France this is very far from being the end of the process.

You will need to apply for a residency card after a certain period (usually three months but different visa types have different rules) and according to your personal situation you may also be required to attend a compulsory medical, language classes and ‘integration’ classes through the French office of immigration and integration (OFII) – more on that here.

3 Health cover

When it comes to health there is some good news – Brits have retained many of their pre-Brexit rights to healthcare.

While you may need to provide proof of private health cover for your visa (depending on the visa type) once you have been resident in France for three months you are entitled to register in the French health system, which covers most of your medical costs.

Full details on how to register HERE.

Brits who are retired and have reached UK pension age also retain their right to an S1 – the status which entitles you to register in the French health system, while the UK continues to pay your medical costs.

4 Remote working

The rise in remote working means that the dream of moving abroad seems much closer for working-age people – since you will be able to work remotely in your native language, maybe even keep your existing job and simply relocate.

While this is possible, you need to do careful research in advance to ensure that work is compliant with your visa and tax situation. Unlike some countries, France does not have a ‘digital nomad visa’ or other visa types aimed at remote workers, in fact the visa rules were written before remote working became widespread, which is why there are some grey areas.

Most lawyers advise getting a working visa (salarié if you are working remotely for a French company as an employee, or auto-entrepreneur for freelancers) and paying social contributions in France. Find full details on visa and tax implications.

You also need to be aware that being a remote working can have an effect on your long-term plans in France – for example if after five years of residence you intend to apply for French citizenship you will need to prove that the ‘centre of your economic activity’ in in France. If all your work is done remotely for foreign companies then this could be a reason to have citizenship refused.

5 Working restrictions

If you want to work in France (remotely or not) you first need to check if there are any restrictions on your profession – certain types of work are ‘regulated professions’ in France, which means you will need specific French qualifications and/or registration within a French guild or professional organisation. The number of professions that are ‘regulated’ is surprisingly wide – taking in everything from chimney sweeping to hairdressing.

The next step is whether your qualifications will be recognised in France – EU countries generally recognise most of each other’s qualifications apart from in certain specific areas like medicine, but this is no longer the case for qualifications gained in the UK – more details here.

There are also certain jobs that are restricted to French citizens only, while others – including working in the public sector in positions including being a librarian – are limited to EU citizens only.

In visa terms, the simplest way for working-age people to come to France is as a salarié (employee) but to do this you will need a job already in place and your new employers will have to act as sponsors for your visa and may also be required to get a work permit for you. All of which means that Brits are less attractive as employees than EU citizens, which makes getting a job harder.

The other option is to be self-employed as either a freelancer, contractor or running a small business – this is a more complicated visa to get, requiring a detailed business plan. Once in France you need to register yourself as a small business/self-employed and register with Urssaf.

6 Tax

If you are living in France, then you will need to do the annual income tax declaration – even if all your income comes from abroad and you are retired/not working in France.

Full details on that HERE.

This was in fact the case before Brexit as well but previously there was a little more flexibility for people who split their time between France and the UK. These days if you want to be here for the majority of the year then you will need a visa/residency card, which removes much of the ambiguity about who is a ‘resident’.

The main post-Brexit difference is the rate at which prélèvements sociaux (social charges, similar to National Insurance) are charged on overseas income (eg earnings from work in the UK or income from renting out a UK property).

The rate is 7.5 percent for income from an EU country and 17.2 percent for income from a non-EU country – after Brexit, UK income switched to the non-EU rate.

7 Driving licence

Foreigners who make France their home will sooner or later need to swap their driving licence for a French one. This too was the case even before Brexit, but many UK or NI licence holders never got round to making the switch, and there wasn’t a lot of enforcement of the rule.

This has now been tightened up and UK/NI licence holders will need to swap their licences for a French one – the exact details of when you make the swap are slightly different for Brits than from other non-EU nationals due to a specific UK-France deal. Find full details HERE.

If you want to bring a car with you from the UK to France, you will also need to re-register it as French – full details HERE.

8 Banks

Most people moving to France will want to set up a French bank account for daily life, but you may also need a UK account, especially if you are a pensioner as some pensions will only pay into a UK account.

However since Brexit some of the biggest UK high street banks have been closing the accounts of their customers who do not live in the UK.

Alternatives include specific ‘expat’ accounts or internet banks – more details HERE.

9 The Brexit Withdrawal Agreement

It’s worth mentioning the Brexit Withdrawal Agreement even though most of it will not apply to newcomers. In brief, the citizens’ rights part of the Withdrawal Agreement covered people who moved to France prior to December 31st 2020, and intended to give them an easy way to remain in France and retain at least some of their pre-Brexit rights.

In general it does not apply to newcomers unless you are a close family member of someone who is covered by the Withdrawal Agreement – either a spouse or civil partner (in which case you must have married/ registered your partnership prior to December 31st 2020) or child. These people have a different path to residency, and can arrive in France and then request residency via the local préfecture of the family member who is already living here.

It’s also worth mentioning because of how different it is to the situation for new arrivals. It’s normal to ask Brits already living in France how they found the whole process – but if someone starts to tell you that getting residency is easy, the first question that you need to ask is when they moved here.

Those here prior to 2021 did indeed get an easy process – they had a special website to apply online for (free) residency cards and received straight away either a 5-year or 10-year card. This is a totally difference process to the one for Brits moving to France now.

If you’re asking around you would be better talking to Americans, Canadians or other non-EU nationals since their process is much more similar to that now in place for Brits.

. . . And new deals/visas/residency permits for Brits

Every now and again UK media will report which great excitement the possibility of a ‘new deal’ for Brits that will make moving to France, or buying a second home here, easier.

These reports should all be taken with a pinch of salt – there are currently no negotiations underway that would affect the process of Brits moving to France, and even if something is proposed in the near future it will likely take years to come into effect because these types of international agreements usually happen slowly.

A proposal for a ‘youth mobility scheme’ from the EU was rejected out of hand by British politicians before it had even been formally offered.

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