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How post-Brexit bank account changes could affect British people in France

As the end of the Brexit transition period looms, the UK has so far failed to negotiate access to the European passporting scheme for banks - here's what that means if you are British and live in France.

How post-Brexit bank account changes could affect British people in France
Photo: AFP

Over the weekend it was reported that, with just three months to go until the Brexit transition period ends, the UK has so far not managed to negotiate a continuation of EU banking rules – known as passporting.

This means that all UK banks will need to apply for new banking licences to provide certain services in each of the 27 different EU countries.

And some banks have apparently decided that this is not worth the hassle in certain EU countries and have begun writing to their British customers registered as living abroad to inform them that they will be closing their accounts or cancelling their credit cards.

Tell us: Have you been affected by the closure of a UK account?

Here we take a closer look at the situation for British people living in France.

Is it all banks?

No, it's important to be clear that there is no blanket closure of accounts for all Brits living abroad, it depends on who you bank with and the type of account you have.

Essentially, applying for new licences will create a lot more admin for banks.

Banks already have to do this for many non-EU countries so clearly it is possible to do. But it seems that some banks are deciding that it's not worth the hassle of doing this for all 27 countries in the EU separately, especially ones where they only have a few customers.

As a country that has a large number of British people living here (estimates vary from 150,000 to 300,000) there is a good chance that banks will decided that it is worth their while to obtain a licence for France.

Is it all account types?

No. Again, this depends on the type of account you have, with straightforward current/checking accounts less likely to be closed.

It could also be the case that certain products become unavailable – for example many Barclaycard customers in France report being told that they will no longer be able to use their credit card.

Is it only if I use my French address?

Many British people living in France use a 'care of' address in the UK for their banking, for example the address of a family member who will forward on all correspondence they receive.

At this stage it seems that only people who have officially changed their address to a French one are receiving letters from their bank.

Can I challenge my bank's decision?

Banks are free to decide what products they offer and to who, but their decisions can be challenged via the Financial Ombudsman Service – find out more about the procedure to file a complaint here.

 

The UK government told British newspaper The Times that “the provision of banking services is a commercial decision for firms based on a number of factors” so Brits in France probably shouldn't hold their breath for any help from that direction.

Which banks?

We have asked all the major names in UK banking what their policy is for customers in France, here are the responses we have received so far. We will update this page as soon as we receive more responses.

Santander – the Spanish banking giant said it was keeping the situation under constant review but told The Local: “We have no current plans to close any of our retail [personal banking] or corporate accounts.”

Lloyds – the bank is understood to be closing business accounts – not personal accounts – of customers living in the Netherlands, Germany, Ireland, Italy and Portugal. However the bank said it had no current plans to discontinue any services for customers in France.

A spokesman said: “We have written to a small number of customers living in affected EU countries to let them know that due to the UK’s exit from the EU, regrettably we will no longer be able to provide them with some UK-based banking services. We want to keep customers informed and offer advice on next steps.”

HSBC – A spokesman for HSBC confirmed on Twitter that current accounts for customers in France would not be affected, provided they were used at least once every 12 months.

Barclaycard – numerous readers of The Local France have been in touch to say that they had received letters from Barclaycard telling them that their account would be closed. Barclaycard is separate to Barclays bank and it is understood that Barclays current accounts are not affected, although the company has not commented on the record so far.

Nationwide – a spokesman said no decisions had yet been taken on accounts held by UK nationals living in the EU. They told The Local: “We are closely monitoring all developments regarding Brexit and are prepared to deal with any outcome.

“Part of this preparedness includes reviewing the ongoing availability of products and services for those members who are resident in the European Union and the European Economic Area.

“Because the outcome of Brexit is not yet clear and the position continues to evolve, there is currently no certainty as to any actions we will be required to take. Regrettably we cannot provide any further detail on the impact on specific products and transactions at this point. However, we will communicate with members as soon as possible about any necessary changes that impact them.”

Member comments

  1. This article on UK bank accounts after Brexit is most imformative. However you mention the response of some of the banks, I wonder if you have had any response from any of the building societies such as the Nationnwide with whom I both bank and have a credit card registered with my French address.

  2. I saw a report elsewhere saying that NatWest had stated that they have no current plans to withdraw banking services from British people with EU addresses, but are keeping the situation under review.

  3. BARCLAYS HAVE NOTIFIED ME THAT THEY ARE CLOSING ALL MY ACCOUNTS WITH THEM, CURRENT AND SAVINGS, DESPITE HAVING BANKED WITH THEM FOR OVER 50YRS. AND NOT USING ANY ‘ADD-ONS’ (i.e. Travel ins., financial advice, mortgage, etc.). I HAVE BEEN TOLD IT IS A BLANKET CLOSURE ACROSS THE WHOLE OF THE EU OWING TO BREXIT, NO MATTER HOW MUCH MONEY IS HELD WITH THEM. I WONDER IF THIS IS ACTUALLY THE CASE.

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BRITS IN FRANCE

6 pension questions British people should ask before retiring to France

If you're British and thinking of retiring to France there are some important questions to think about before you make the move, and before you make any decisions about your UK pension.

6 pension questions British people should ask before retiring to France

Retiring to France is a dream for many, but before turning that dream into reality there are some serious financial questions that you need to ask yourself to ensure that your retirement is a financially comfortable one.

For most retirees, their main or only income will be a UK pension, so it’s important that you understand how your pension will work once you make the move. 

There are some specific rules and restrictions on taking pensions out of the UK, while there is also the question of how UK pensions interact with the French tax system.

Financial adviser, Maeve Hoffman, from Spectrum IFA Group, emphasised that people should not take these decisions lightly, telling The Local: “Figuring out what to do with your pension should be part of your wider financial plans for your life.

“This may be your most important asset, besides your home, and the best answer for what to do with your pension is highly individual. There are no sweeping generalisations when it comes to advice on private pensions. Everyone’s situation is different,” she said.

This article is intended as an overview of how the system works for UK pensioners and is not intended as a substitute for individual financial advice. The article is aimed at people who have worked most or all of their career in the UK and then intend to retire in France – the situation is slightly different for people who work in France and then retire here.

You can find an overview on French tax rules for pensions HERE.

Long-term or short-term

The first thing you need to carefully consider is whether or not your move to France will be for the long-term or short-term. 

When it comes to your UK pension, there are some options that may be advantageous for French residents looking to stay here permanently, but they could make your life very complicated if you end up returning to the UK in the future. 

Do not be afraid to ask yourself the tough questions – is there any chance you will have grandchildren in the future that you will want to be geographically close to? Have you ever spent a significant time in France, aside from short holidays? Do you have roots in France, such as friends, family or a home? If your health deteriorates, will you want to be cared for in France or the UK?

If are unsure about the answers to these questions, then take some time to really think about them. There are alternatives to permanently moving to France if you are unsure – for example, you could spend a few months a year here on a short-term visitor’s visa.

READ MORE: Reader question: Can I retire to France and open a gîte?

Understanding the different tax rules

British retirees should be aware that the UK and France have very different tax systems.

Once you become a tax resident in France, you have to file a yearly declaration, including your global income. The country that gets to tax that income is determined based on the tax treaty between the UK and France, which seeks to eliminate double-taxation. 

READ MORE: EXPLAINED: The rules on tax residency in France

As for your UK-based pension, the treaty states that if you have a UK government or civil service pension (eg a state school teachers’ pension), then this will remain taxable only in the UK. Some old NHS pensions were considered ‘government pensions’, but modern ones might not be. You can check if your pension is classified as ‘government’ here.

You still have to declare this income to the French tax authorities, but you will not be subject to tax in France on it. That being said, it will count towards your total household income, and could end up pushing you into a higher tax bracket which is something you should carefully consider, particularly if you want to take a large sum at once. 

The same is not true of private pensions: these are taxed in France, not the UK, as soon as you become a tax resident here. Confusingly, the UK state pension is also considered a private pension, even though it is paid by the government.

You can find a complete guide to how UK pensions are taxed in France HERE.

As a result, you will want to think about whether your previous plans for your private pension were only advantageous to you as a UK resident. Once you become a French tax resident, they could have unforeseen implications.

You can find more information about tax rates in our tax guide. 

Get reliable, expert financial advice before doing anything

If you have decided you want to be in France permanently, then you will need some expert tax and pension advice – but you need to be careful who you take advice from, this is a highly specialist area and it’s unlikely that high street financial advisers will have the knowledge that you need. 

Brexit has also made getting financial advice more complicated, with fewer experts available.

Maeve told us: “Because of Brexit, you cannot use a UK-based financial adviser anymore – you have to use an EU-registered one. This has made things more complicated. When picking an adviser, seek out someone who has expertise on the local taxation rules in France. They should also be regulated with the financial regulator where you live and where they work.” 

It can be especially complicated to parse out who you can and cannot take advice from – for example, some UK-based advisers have continued to give advice to EU-based clients, even though this can be particularly risky if the investments they recommend do not follow EU regulations.

There are also expat-oriented financial advice services that are located outside of France, but seek to offer tax advice to people in France.

She added: “Be smart and sensible. If you choose an adviser in Dubai or Spain for example, you will now be adding another regulatory organisation into the mix, plus another language.

“There are free, government-based services in the UK that can help you understand your private pension – Pension Wise and Money Helper. Before doing anything, you should consult the free services. Any financial adviser worth their salt would recommend this too. 

“These services have begun to have longer wait times, so be sure to book well in advance of when you plan to draw from your pension.”

Deciding whether to transfer your pension

Another question that is important for Brits to think about is whether or not to transfer their pension into either a UK-based SIPP for non-residents, or a QROPS (Qualifying Recognised Overseas Pension Schemes).

The SIPP will keep your pension in the UK, while the QROPS moves it out of the UK, to Malta specifically. 

These options can be helpful for French residents, but you need to familiarise yourself with their benefits and drawbacks.

“The QROPS is not for someone who is unsure of their future in France, as if you return to the UK within five years of the pension transfer HMRC will seek their tax back as if it was a full encashment,” Maeve said.

In France, a QROPS is considered a trust, you may also have additional reporting requirements to fill out along with your annual declaration (more info here).

You should beware of scams on this subject, as the post-Brexit period saw many scammers seeking to persuade Brits that it was now mandatory to transfer their UK pension – always be wary of any cold-calling or unsolicited financial advice.

READ MORE: Ask the expert: How to avoid pension scams when you retire to France

Determining how you will want to draw from your pension

The next question is how you want to receive your pension – either as regular income or as a lump sum. The option that you chose will have tax implications in France.

If you receive it as a regular income, when doing your yearly French tax declaration, you will add up your pension income for that year and you will be taxed at the normal marginal rates for income (the barème). These rates go up to 45 percent (for the highest earners only) plus social charges if they apply (more on this below).

Pension income can also benefit from a 10 percent tax deduction, as long as it does not exceed €4,123 or fall below €422 per household.

Lump-sums are more complicated. Technically, French tax authorities would allow a return of once off pension capital to be taxed at a flat rate of 7.5 percent. 

But in reality, Hoffman explained that anyone seeking to do this would need the express, written confirmation from French tax authorities that this rate will be applied.

She also explained that the type of private pension matters when seeking to get the lump-sum flat rate.

“There are plenty of different types of private pensions in the UK, but the old ‘defined benefit schemes’ have been the gold-plated standard. These are the types of pensions that give you a portion of your salary for the rest of your life. 

“In principle, you should be able to take out lump-sum of 25 percent of your ‘defined benefit scheme’ pension and be taxed at the 7.5 percent flat-rate. That being said, some people get refused, so you cannot make any assumptions and you need clarification from the French tax office.

“As for all of the other types of private pensions in the UK, like the money purchase or personal pension schemes, these are considered to be ‘funds’. If you want to benefit from the lump-sum then you would have to take out the entire pension. You would not be able to just take out 25 percent and get the lump-sum rate.

“For anyone considering taking their whole pension and seeking to use the 7.5 percent rate there are conditions to be met, so I advise people to write to their French tax office and explain their own situation in detail. Be sure to clarify the tax rate you are seeking to have applied and ask what documents they would need from your UK pension company to confirm that the contributions to this pension have been tax deductible.”

Healthcare and social charges

Deductions in France come in two types – impôts (income taxes) and prélèvements sociaux (social charges).

People who retire to France (and have never worked in France) and have already reached the state pension age can apply for the S1 – this means that the UK continues to pay for their healthcare costs and they would not be charged prélèvements sociaux. Non-working spouses of an S1 holder can also benefit from this.

People who take early retirement and make the move before they reach state pension age may have to pay social charges in addition to taxes until they reach the state pension age and can apply for their S1. However, there are several exemptions to social charges, so even if you expect a bill, you may not end up being charged. More information in our guide.

Social charges help pay for a lot of services from the French government, including access to healthcare. In France, you can access the state healthcare system (and get a carte vitale) after three months of residency. 

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