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BREXIT

From ferries to Eurostar: How Brexit has hit travel between France and the UK

The effects of the UK's exit from the EU continue to be felt on travel between France and the UK, two years on from the end of the Brexit transition period - and it's likely there is worse to come.

From ferries to Eurostar: How Brexit has hit travel between France and the UK
Photo by ERIC PIERMONT / AFP

When it comes passenger travel between France and the UK, there have been three main changes since the end of the Brexit transition period on January 1st 2020; stricter and more time-consuming border checks, passport stamping for non-residents and a passport requirement for French/EU citizens.

Travel to France: What has changed since Brexit?

And these changes have also had a knock-on effect on the transport services and links between France and the UK.

The UK was never part of the Schengen zone, so passport checks happened at the UK-France border even pre-Brexit, but there are now extra rules in place.

For Brits coming into France who do not have a French visa or residency card, their passports must now be stamped in order to enforce the ’90-day rule’ – pre Brexit there was no limit on how long people can spend here. Passport stamping is more time-consuming than simply having to check a passport and this – combined with other extra checks such as pet passports or goods imports – mean that crossing a border point is now a more time-consuming process.

French or EU citizens wishing to enter the UK now need a passport – previously an ID card was sufficient. Because the ID card issued to all French citizens is enough to travel around the whole of the EU, only around half of French people have a passport. 

The Covid pandemic coincided with the end of the Brexit transition period, so it’s not always easy to pick apart the effects of each event, but here is what transport bosses say about the impact of Brexit on services.

Eurostar

The Eurostar is in trouble, and the company CEO says two things are to blame; Brexit and the pandemic.

In a revealing written statement to British MPs last year, former Eurostar CEO Jacques Damas said that peak capacity at both London St Pancras and Paris Gare du Nord was 30 percent less than it was pre-Brexit, because of the increased infrastructure needed to check and stamp the passports of travellers.

He said: “Even with all booths manned, St Pancras can only process a maximum of 1,500 passengers per hour, against 2,200 in 2019.

“It is only the fact that Eurostar has capacity-limited trains and significantly reduced its timetable from 2019 levels, that we are not seeing daily queues in the centre of London similar to those experienced in the Channel ports.

“This situation has obvious commercial consequences and is not sustainable in the mid to long-term.”

The main effect on passengers is twofold – fewer services and higher prices in order to keep the company afloat.

As anyone who has travelled on the service will know, check-in spaces at both London and Paris are quite limited, and Damas says that in order to prevent huge queues the trains will have to keep running at a limited capacity.

Several services have also been cut – including the direct route to Disneyland Paris, special ski trains and stops at Ashford in the UK – as the company battles to stay afloat, its woes compounded by huge commercial loans it was forced to take out to stay afloat during the pandemic. 

Damas’s successor as CEO at Eurostar Gwendoline Cazenave also revealed that peak time morning services between Paris and London are forced to operate with hundreds of empty seats due to the post-Brexit processing times meaning border control cannot process passengers quickly enough.

“The pity is we cannot offer enough seats because of these station bottlenecks,” Cazenave said.

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Chief commercial officer, François Le Doze admitted the caps on seat numbers were pushing prices up.

As well as higher prices Brexit also meant passengers are advised to arrive much earlier at either St Pancras or Gare du Nord – 90 minutes before departure – compared to 2019 when 30 minutes was usually enough. 

Channel ferry ports

Just as the Eurostar operators are finding, the extra passport control checks are simply taking more time, and at peak times this means queues. 

The UK-France border is unique in Europe, in that British and French border officials work together in the ports of Dover and Folkestone, as well as at London St Pancras and Paris Gare du Nord stations.

This arrangement – due to the Le Touquet agreement – means that if you’re boarding a ferry in Dover your passport will be checked twice, first by British officials and then by French, but when you arrive into Calais you will simply drive off. The same applies in reverse.

This makes traffic more fluid on arrival, but the double passport checks can see long queues at check-in. The start of the summer season in 2022 (the first time that traffic returned to normal after the pandemic) saw queues of more than six hours at Dover. Many were quick to blame French officials for arriving late for work, but longer check-in times means that any delay can quickly escalate. 

At peak times passengers at Dover have been told to allow for up to two hours to complete all checks before departure.

Eurotunnel trains

As mentioned above the longer processing times at passport control have also affected the Eurotunnel shuttle service between Calais and Folkestone. It now takes drivers longer to pass through the processing checks given the extra post-Brexit passport checks.

Folkestone’s Channel Tunnel port was also labelled “the hotspot of holiday hell” in July 2022 when it was hit by the same kind of travel chaos and mammoth delays as the nearby ferry port at Dover.

Channel island ferries  

Travel between the UK and Channel islands has been unaffected by Brexit since the islands are UK crown dependancies, but travel between France and the islands (a distance of around 60km) now requires a passport.

The Jersey Minister for Home Affairs, Deputy Helen Miles, announced via press release that French visitors to the island will no longer need to present a valid passport to visit for a day trip as part of a new provisional scheme.

Instead, French day travellers will be able to travel on commercial ferries using just a national ID card. 

Miles explained that the objective is for the scheme to be put into practice prior to the start of the summer season (which typically begins in April) this year. In September, the programme will be judged and a more permanent decision will be announced.

The move comes after local authorities in the French département of Manche said that visitor numbers from France to the islands have halved since Brexit, blaming the requirement for a passport, which many of their usual passengers do not have.

Prior to 2019, boats going to and from the French mainland carried at least 110,000 people per year. In 2022, only 40,000 passengers made the journey, Olivier Normand, the sales manager of Manche Îles Express, told Actu France.

The local ferry service is subsidised by Manche authorities, who said they may have to axe the line altogether if a solution was not found prior to the summer season. 

Local authorities in France have said they are hopeful about the provisional scheme lifting passport requirements to Jersey, but are still calling for the same to be made available for the neighbouring island of Guernsey. 

Flights 

Flights have been the least affected by the post-Brexit changes, largely because airports already had lengthy and time-consuming check-in and security processes in place, and having to check in several hours before your flight time was normal.

School trips

The UK used to be a major destination for school trips by French groups, particularly schools in northern France which could make a day trip to the UK.

However the passport requirement makes things much more difficult for schools, since many of their pupils won’t have a passport. Visa rules also means that any child in the class who is not a French citizen may require a visa in order to visit. The extra paperwork has proved too much of a burden to many teachers, who have stopped UK trips altogether.

More problems to come?

Usually you would expect things to get better as everyone gets used to new systems, but several transport bosses have sounded the alarm about new systems due to come into effect later this year. 

These are two changes to how the EU polices its external borders – which since Brexit includes the UK-France border – known as EES and ETIAS.

You can read the full details HERE – but they include the introduction of a one-off €7 visa for tourists and biometric checks at the border. 

Just like the changes already in place, they will simply be more complicated and time-consuming at the border – and Channel port bosses are particularly worried because the process does not appear to be designed with car passengers in mind.

The boss of the Port of Dover told The Local that he fears “queues throughout Kent” when the first part of the process – EES – comes into effect. This was due to start in May, but has now been pushed back to later in 2023. 

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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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