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PENSION

What to know about your French pension if you worked in another EU country

If you have worked and paid pension contributions in both France and another EU country - including pre-Brexit Britain - then here is what you can expect for how your combined pension will be calculated.

What to know about your French pension if you worked in another EU country
The EU flag and flags of other nations are pictured at the European Parliament in Strasbourg, France (Photo by FREDERICK FLORIN / AFP)

It is common for people to work in more than one country during the course of their career, and they usually end up paying pension contributions in each country. However it is not always clear how these are combined once you reach retirement age. 

This is the situation for people who have worked in France and another EU/EEA country or Switzerland. For those who have worked in a non-EU country, click HERE. For Brits, go to the bottom of the article. 

French pension

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. 

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

In France, because the pension system is “pay-as-you-go”, you are technically eligible for a French pension after just one quarter (trimestre) of working in France under a French contract, though the value of the pension after just one quarter would be quite low.

You can use the French government pension simulator to check the level of your French pension – full details HERE on how that works.

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

Non-French pension

In general, periods of employment outside France may be combined with years worked in France to boost or qualify for the French state pension. However, it depends on which country you have worked in, and whether that country has a social security agreement with France.

All EU, EEA countries, and Switzerland have social security coordination, so will have their pension contributions made in France calculated in the same way as for EU/EEA countries.

Retirement age

The first step is to look at how many EU/EEA countries you have worked in, and to check your retirement eligibility under each of those regimes.

For example, if you worked in both Denmark and in France, then you must consider the minimum age of retirement in both countries. If a person retired at the French legal age of 64, they would receive only the French portion of their pension until they reached Denmark’s legal retirement age (66 to 68), when they would start getting the Danish portion as well. 

Pension rates

Then, a calculation is done to determine the pension rate. This will look at the person’s would-be pension under the French scheme (also known as the national pension, or independent benefit). Another calculation will also be done to determine the pension rate under the European community formula (also known as the pro-rata benefit). In most cases the higher value will be the pension applied.

On the European Commission’s website dedicated to explaining old-age pensions across the EU, the European authorities explain how this double calculation is done. Taking the example of the hypothetical person “Rosa” who has worked 20 years in France and 10 years in Spain, the EU site explained how the two European countries would determine who pays what portion of Rosa’s pension.

Starting with France, the first calculation made determines Rosa’s current pension under the French scheme – which is based on Rosa’s 20 years contributing to the French pension system. It is determined that she is entitled to €800 per month.

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

The next calculation uses the European calculation that offers a theoretical amount – the pension Rosa would receive had she worked the entirety of her career in France.

This theoretical calculation determines that for 30 years working in France, and it determines Rosa would earn a €1,500 pension. To figure out the portion of Rosa’s total pension that France will pay, French authorities multiply Rosa’s would-be total pension (€1,500) by the 20 years worked in France. Then, they divide that by the total years worked in both countries (30 years).

This finds that ultimately France will pay Rosa €1,000 per month as her French pension.

As for the Spanish side, pension authorities will also look at Rosa’s “pro-rata” (or theoretical pension) if she had worked the entirety of her career in Spain. They determine that she would have received a Spanish pension of €1,200 for a full career. Then, Spanish authorities do the same European calculation where they multiply Rosa’s would be total pension (€1,200) by the number of years worked in Spain (10). They divide this number by the total number of years worked (30) to get the portion of Rosa’s total pension that should be paid by Spain.

This determines that Rosa ought to receive €400 of her pension from Spain.

In total, she will receive a pension of €1,400, but €1,000 will be paid by France, and €400 will be paid by Spain. 

You can see more examples of these calculations with specific simulations at the Europa.EU website page for State pensions abroad. 

You can also watch this video, made by the European Commission, to understand how the process works for EU nationals.

The case for Brits

Brexit has made pensions more complicated for Brits, and essentially divides British workers into two groups.

Those who arrived in France before December 31st 2020 – and are therefore covered by the Withdrawal Agreement – continue to benefit from EU social security co-ordination. They should therefore have their pensions calculated as described above.

Those who moved to France after December 31st 2020 are treated as non-EU nationals for pension calculations – click HERE for a full explanation of the system for non-EU workers.

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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PROPERTY

What restrictions are there on foreigners buying property in France?

Purchasing property in France as a foreigner has several extra hurdles - here's a look at some of the restrictions and other challenges you will want to be aware of beforehand.

What restrictions are there on foreigners buying property in France?

There are several things to consider before buying property in France. You may want to visit the area during different seasons to be sure that you enjoy it rain or shine, and you will want to consider how much you would end up paying in property taxes, as well as whether or not it will be a main residence or second home.

The law

Let’s start with the good news – there are no official rules in France against non French-citizens purchasing property, neither is there any requirement to be resident in the country in order to buy property – indeed foreign second-home owners make up a small but significant slice of the property market.

Revealed: Where in France do foreigners buy second homes

But in practice there are a number of challenges foreigners face when buying French property, especially if they need a mortgage.

Property sale process

Before making your decision, learn the steps to buying property in France and the expected timeline.

Roughly, there are five steps: making your offer, a cool-off period, signing a ‘Compromis de Vente‘, providing the notary (notaire) with your deposit, and signing the ‘Acte Authentique de Vente‘ (deed).

READ MORE: How long does it normally take in France to buy a property?

The French property purchase system is likely to be different to what you are used to – especially the role of the notaire.

Also Americans might be surprised to learn that in contrast to the US system of having a realtor who guides you through the entire process, in France – as in most of Europe – buyers are expected to do much work of the house-hunting work themselves.

Bureaucracy

There are a few extra steps added if you need a mortgage, but generally all foreign buyers should be prepared to have a valid ID (passport), as well as other documents including your marriage and/or divorce papers (to demonstrate your civil status).

At some point in the process, you will need to open a French bank account, even if that ends up just being for utilities after you’ve made the purchase. The earlier you can open a French bank account, the better.

You should know that purchasing property in France does not automatically give you residency rights. If you are not an EU citizen, then you will need a residency card or visa to spend extended time in France.

READ MORE: EXPLAINED: What type of French visa do you need?

Getting a mortgage

While there are no laws stopping foreigners from buying property in France for most people the biggest obstacle is getting a mortgage, as there are conditions that many foreigners cannot fulfil.

In France, the vast majority of loans are guaranteed by banks, and one bank’s offer to you may not be the same as another’s. You are free to contact several banks to find the best offer for your situation.

READ MORE: French property: How to get a mortgage in France

While there are alternative options besides banks, such as a ‘vendor loan’ (prêt vendeur) – where one sets up a credit contract directly with the seller of the property via a notary – this is much less common.

The biggest issue is that banks will require that foreigners prove that they will be able to legally remain in France for the entirety of the repayment period. As such, it can be very challenging those on short-term residency cards, to be accepted for a mortgage loan.

For the same reason, it is very difficult for non-residents to get a mortgage via a French bank.

Foreigners can also consider international options, or independent, specialised mortgage brokers, like those geared toward expats – however some have minimum income levels and minimum property purchase prices.

Another point to keep in mind is the fact that French banks also look favourably on ‘stable’ employment statuses, such as CDI (indefinite) work contracts, which, by their calculation, reduce risk of unemployment. It’s not impossible to get a mortgage if you are self-employed, but it’s harder.

Additionally, age can be a factor – lenders tend to be less likely to award mortgages to those nearing or above retirement age.

Americans – The situation is even more challenging for Americans in France, as banks can be reticent about working with Americans due to FATCA – which, according to the US dept of treasury, requires that “foreign financial institutions (FFIs) report to the IRS information about financial accounts held by US taxpayers, or by foreign entities in which U.S. taxpayers hold a substantial ownership interest.”

This has forces French banks to collect and maintain more information about their American customers. If the banks fail to disclose information to the IRS, they risk exclusion from the US market as well as penalties.

In a survey about the effects of citizenship-based taxation on Americans in France, one respondent said: “Multiple banks have denied me a mortgage because I am American.

“We used the services of a mortgage broker and when we went in for the final presentation a few weeks ago, only one out of the many banks queried offered us a mortgage, and it wasn’t even a good offer.”

READ MORE: Divorce, stress and fines: How citizenship-based taxation affects Americans in France

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