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PENSIONS

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.

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

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.

READ MORE: Ask the experts: What do Americans in France need to know about investments and pensions?

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).

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

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. 

READ MORE: Brexit: How to avoid bank account closures by opening a French bank account

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.

READ MORE: Australians planning to retire to France warned over little-known pension trap

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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LIVING IN FRANCE

5 things Brits in France need to know about swapping driving licences

Now that the dust has settled from the somewhat chaotic post-Brexit period, the system for swapping a UK driving licence for a French one seems to be running fairly smoothly. There are, however, some things that UK licence holders need to know.

Published: 3 May 2024 17:20 CEST
5 things Brits in France need to know about swapping driving licences

This article is aimed at holders of a UK or Northern Ireland driving licence who are living in France – tourists, visitors and second-home owners can continue to drive in France on a UK licence and do not need an international driving permit.

British students who are studying in France on a student visa can continue to drive on their UK licence during their studies – if however they settle in France afterwards, they need to follow the below process for swapping their licence. 

1 You’re special

Well, maybe special is over-stating it, but the system for holders of UK and NI licence holders is different to that of other non-EU nationals, and also different to the system for EU licence holders.

The reason for this is that a pragmatic post-Brexit agreement was (finally) reached between France and the UK, in order to avoid the chaos that was triggered when thousands of Brits in France all tried to swap their driving licences at once.

Unlike almost all other post-Brexit agreements, this one applies both to people who moved to France before the end of Brexit transition period in 2021 and those who have moved here since. 

The below terms apply to everyone who has a UK or NI licence, regardless of their nationality or when they moved to France. 

2 But you still have to swap

It was technically always the case that Brits who were living in France should have swapped their licence for a French one, just as other EU licence holders do now, but in reality many people lived here for years or decades without ever exchanging their licence and there was little or no enforcement of the rule.

That has now changed and you must swap according to the following timetable;

If your UK licence was issued after January 1st, 2021 – you must swap within one year of moving to France.

If your UK licence was issued before January 1st 2021 – you only swap when you meet one of the following conditions;

  • The licence itself or the photocard is within six months of its expiry date. For more people the photocard expiry will come around first, but UK licences also require renewal when the holder reaches the age of 70
  • Your licence has been lost or stolen
  • You have been ordered to exchange your licence by a gendarme after committing a driving offence

For people who are exchanging because the licence is about to expire, it is important that you don’t start the process until your licence is within six months of the expiry date – early applications will simply be rejected.

3 It might not be as much of a nightmare as you think 

Unlike the old days when licence swaps were done by préfectures, the whole process has now moved online and is run through a single, central system.

The online portal for requesting a swap is known as ANTS and you can find it HERE.

If you haven’t used it before you will need to create an online account, or if you already have online accounts for French government services such as Ameli or tax declarations you can login by clicking on the France Connect button.

Once logged in, select Je demande l’échange ou l’enregistrement de mon permis de conduire étranger (I request the exchange or registration of a foreign driving licence) and fill in the details requested on the form such as name, address etc.

You might be pleasantly surprised by the fact the form itself is relatively straightforward (as French admin forms go), asking basic questions such as your personal details and the details of your driving licence.

You will have to upload supporting documents, but these are likely to be things that you already have to hand including

  • Proof of ID (passport or carte de séjour)
  • Proof of address (a recent utility bill or attestation from your utility provider)
  • If your driver’s licence is in a different name to your passport, you will need to supply your full birth certificate

You will also need to supply a photo – you can either use the internet-enabled Photomaton booths – find your nearest here – to create a digital photo with the required security code, or you can use the normal photo booths to print out a physical photo and send it by post after you have made your application. 

Once completed, you can use the ANTS site to track the progress of your application and upload any other documents that are requested.

4 But don’t leave it too late 

If you’re applying because your licence is about to expire then you cannot apply until you are within six months of the expiry date.

But it’s a good idea not to leave it until the last minute as the whole process does take time – things have improved massively since the dark days of 2020 and 2021 when people were waiting for years and their licences expired while they waited.

But it still takes time – the current average for a straightforward application with no extra documents required seems to be between four and five months, although processing times can vary, especially over holiday periods.

It’s therefore a good idea to make the application fairly soon after you enter that magic six-month window.

Once you make the application you should get an automated response acknowledging receipt – this is usually sent by SMS and/or email, it’s a good idea to check your spam folder if you don’t get the email.

Don’t panic if you don’t then hear anything for the next few weeks or even months, this appears to be normal. If your application is complete and there are no outstanding queries or other documents required, the next step will be a request to send in your old UK licence.

You send this by post (recorded delivery with a signature is strongly recommended) and at the same time you can download an Attestation de Depot de Permis de Conduire (certificate of deposit of driving licence) – you can use this to prove your continued entitled to drive in the period between sending in your old licence and receiving your new one.

Your French licence is then sent by registered post, and the window between posting the old licence and receiving the new one is usually not more than a month, you 

5 Help is out there 

If your application runs into problems or you have an untypical situation or find the ANTS website hard to use, don’t panic – help is available.

The Facebook group Driving in France – French Licence Applications is a good place to start with comprehensive guides and knowledgeable admins who are quick to respond to questions.

You can also chat to others in your situation and get updates on how long processing times seem to be.

If you have problems using the online system, your local France Services office may be able to help.

You can also head to The Local’s reader questions section, or email us at [email protected] if you have questions.

Digital licences

You might have heard about France’s new digital driving licence – unfortunately this is only available to people who have French citizenship (including dual nationals).

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