SHARE
COPY LINK
For members

BREXIT

Brexit: What Brits in Austria need to know if they intend to move back to the UK

Most people accept that moving to Austria is tricky and involves a lot of paperwork, but for Brits deciding to go back to the UK it's easy, right? After all, you're just going home. Wrong.

Brexit: What Brits in Austria need to know if they intend to move back to the UK
What do Brits in Austria need to do if they intend to return to UK? Photo by Oli SCARFF / AFP

Moving countries is a time-consuming process – but if you’re British and living in Austria you might think that moving back to the UK would be simpler.

Well, there won’t be a language barrier and as a UK citizen you won’t need any immigration paperwork (although if you’re bringing an Austrian or other foreign partner with, then that gets complicated) – but you will still face administrative hurdles around pensions, healthcare, driving and taxes. 

Some of these issues existed before Brexit, while others are a direct result of the UK leaving the EU. Here are the most common questions from Brits thinking of moving back to the UK: 

Do I still qualify for NHS treatment?

You are entitled to NHS treatment if you are ‘ordinarily resident’ in the UK – there is no minimum time limit so as soon as you are back in the UK on a permanent basis, you can use the NHS.

Getting back on the NHS might be one of the easier parts of moving back to the UK. Photo: Pixabay

You will need to register for a GP in your local area in order to access non-emergency treatment and to get an NHS number if you do not already have one.

You may need to provide proof of a UK address in order to use NHS services – although in reality UK citizens are rarely asked for this, apart from when registering with a GP. 

If you have been an S1 holder while living in the EU you should cancel that, just so there is no confusion over where you are getting your healthcare.

If you go back to Austria or elsewhere in Europe for a visit, remember that you are now a tourist and will need a GHIC card to get European healthcare, while travel insurance is also advised in case of an accident or illness while visiting an EU country. 

Can I drive on my EU licence in UK?

If you have been living in the EU you may have had to change your UK licence for a French or Spanish one for example.

Once you’re back living in the UK you can continue to drive on you EU licence until the age 70 or if you move to the UK when you are 67 or over you can drive for three years. After this time you’ll need to change your licence.

If your licence or photocard has an expiry date – once it’s time to renew, you should swap it for a UK licence. You’ll need a valid photocard licence to drive in the UK.

You can find details on the swap process for UK licences here, and if you’re in Northern Ireland here

UK residents with an EU licence can if they want exchange their licence for a UK one, if they wish to do so, without the need for a re-test.

Can I bring my Austrian partner with me?

If you’re returning alone you won’t need to do any kind of immigration paperwork, your UK passport is enough. However, if you are bringing with you a partner who is not a UK citizen, it becomes complicated.

After the end of the Brexit transition process, there was an ‘amnesty’ period in which Brits with EU partners could move back to the UK under the old immigration rules. This is now ended and EU partners face the same immigration process as all other foreign spouses.

Essentially either your partner will need to have already secured a relatively high-paying job in the UK, or you will need to prove that you have a large amount of money to support them.

They will need to go through the process of getting a UK visa (which is expensive – between £1,000 and £1,500 just for the visa fee) and there is no guarantee that their application will be successful simply because they are married/in a civil partnership with a Brit. They will also need to take an English-language exam. 

Full details here. 

What about my pension contributions from the EU? 

If you have been working in Austria, you will probably have been contributing to the Austrian pension system. Pre-Brexit, UK and EU pension contributions could be blended into a single pension – but this is no longer the case.

Brits still living in the EU who are covered by the Withdrawal Agreement are theoretically covered by blended pensions if they had made pension contributions in the UK before moving to the EU, but the same does not apply if you move back to the UK. 

The good news is that EU countries still practice this – so if for example, you have worked in France, Italy and Austria, your contributions will be totted up and paid out as a single pension – you apply in the last country you worked in.

Brexit ended the easy movement of pensions between the EU and UK – something you’ll need to keep in mind if you move back. (Photo by Centre for Better Ageing / Pexels)

Keep in mind, however, that different countries have different pension ages. So if for example, you worked in Austria (pension age 65) and Greece (pension age 67) – you will start to get the Austrian portion of your pension from the age of 65, but you won’t get the Greek part until you turn 67.

The country that is paying your pension may require you to have an EU bank account to pay into – and you should check with the country paying your pension whether there are any other conditions to observe.

READ ALSO: EXPLAINED: Do your pension contributions abroad count in Austria?

When it comes to a pension from the UK, it depends on how long you worked there – the basic rule is that you need 10 years of National Insurance contributions in order to get a state pension.

However, the UK government states that periods of work done in the EU or EEA ‘may’ count towards your qualifying period. Even if they do, however, they don’t count towards the total pension amount – so for example, if you worked for seven years in the UK and the remaining 35 years of your career in the EU, you can qualify for a UK state pension, but it will only be based on the seven years of work in the UK (in other words, the payment per month will be tiny).

Further details on UK pension entitlement.  

Do I need to hand back my residency card, health card etc. before I leave the EU? 

Most countries require that you hand back residency cards before you leave, but this is not always enforced. If you’re in Austria, however, this is a good idea so you don’t face any further issues. It can also help prove to the Austrian tax authorities that you’re no longer living and working there.

In general too, Austria will require you to de-register with your local authority upon leaving the country. This may work out a bit differently if you continue to own a second home in Austria, but even then, you may need to declare your Austrian home as such with the local authority.

If you do end up keeping residency or healthcare cards – don’t use them on trips back to the EU. Tempting as it might be to avoid border queues, you will create a confusing official record if you are claiming to be a resident of two countries at once.

If you have taken up Austrian citizenship, that is a different matter of course. 

READ ALSO: What do dual-nationals need to know about post-Brexit border controls

Do I still have to pay Austrian taxes? 

It’s highly likely that you were paying taxes in the country you lived in. Generally, tax declarations concern the previous year, so you will have to do at least one tax declaration and payment after moving back to the UK.

In Austria, the annual tax declaration takes place between April for paper filing and June for electronic filing, and concerns the previous calendar year. So if for example, you move back to the UK in September 2023, you will have to electronically complete an Austrian tax declaration before the end of June 2024, covering your 9 months of residency in Austria in 2023.

Someone doing their taxes.

Moving back to the UK won’t get you out of doing one last Austrian tax return. Photo: Pixabay.

If you still own property in Austria you will pay non-resident property taxes there. 

When you left the UK, you will likely have informed HMRC that you were leaving the country, so you will now have to tell them that you’re back. Whether you have to fill out a UK self-assessment form depends on whether you are a salaried employee or self-employed/retired. 

Can I keep my Austrian bank account? Do I need a new UK account? 

This one depends on the policy of your bank, but some banks in Austria may require you to have an Austrian address.

It’s likely that your UK bank may have closed your account if it was not operational while you were living outside the UK, in which case you will need to open a new one.

A practical option while you are moving and still have interests in both countries is to open an internet bank account with a company like Wise or Revolut – these offer accounts in both pounds and euros and give you a European IBAN and a UK Sort code, so you can use it in both countries.

Will my EU qualifications be recognised?

If you were studying or gaining professional qualifications while living in the EU, don’t assume that these will be recognised in the UK. Brexit ended the mutual recognition of qualifications – check with the professional or academic body that issued them whether these are recognised in the UK, you may need to acquire a certificate of recognition.

It’s a good idea to check this point before you start job-hunting in the UK. 

Be prepared for hassle

The advantage of moving back to the UK is that you’re not starting from scratch and at least you know how things like council tax, electricity billing and healthcare work.

However, don’t assume that it will all be plain sailing – your lack of a recent UK address will make you an anomaly in many companies’ systems and you’re likely to be forced to have several long and annoying conversations with call centres while you explain that while you are a UK citizen, you have not recently been living in the UK.

There are likely to be other niggles too – many UK car insurance companies won’t recognise a no-claims bonus built up abroad, so you’ll be back to paying full premiums on your car insurance, while banks might request extra money laundering checks due to your foreign associations.

Banner ad

A lot of people in the UK also seem to be confused about the difference between citizenship and residency, so be prepared to have the following conversation a lot: “I’ve recently been living in Spain. No, I’m not Spanish, I’m British, I was just living in Spain. Yes, I am a UK citizen.”

Member comments

Log in here to leave a comment.
Become a Member to leave a comment.
For members

EES PASSPORT CHECKS

How will the new app for Europe’s EES border system work?

With Europe set to introduce its new Entry/Exit biometric border system (EES) in the autumn there has been much talk about the importance of a new app designed to help avoid delays. But how will it work and when will it be ready?

How will the new app for Europe's EES border system work?

When it comes into force the EU’s new digital border system known as EES will register the millions of annual entries and exits of non-EU citizens travelling to the EU/Schengen area, which will cover 29 European countries.

Under the EU Entry/Exit System (EES), non-EU residents who do not require a visa will have to register their biometric data in a database that will also capture each time they cross an external Schengen border.

Passports will no longer be manually stamped, but will be scanned. However, biometric data such as fingerprints and facial images will have to be registered in front of a guard when the non-EU traveller first crosses in to the EU/Schengen area.

Naturally there are concerns the extra time needed for this initial registration will cause long queues and tailbacks at the border.

To help alleviate those likely queues and prevent the subsequent frustration felt by travellers the EU is developing a new smartphone app.

READ ALSO: What will the EES passport system mean for foreigners living in Europe?

The importance of having a working app was summed up by Uku Särekanno, Deputy Executive Director of the EU border agency Frontex in a recent interview.

“Initially, the challenge with the EES will come down to the fact that travellers arriving in Europe will have to have their biographic and biometric data registered in the system – border guards will have to register four of their fingerprints and their facial image. This process will take time, and every second really matters at border crossing points – nobody wants to be stuck in a lengthy queue after a long trip.”

But there is confusion around what the app will actually be able to do, if it will help avoid delays and importantly when will it be available?

So here’s what we know so far.

Who is developing the app?

The EU border agency Frontex is currently developing the app. More precisely, Frontex is developing the back-end part of the app, which will be made available to Schengen countries.

“Frontex is currently developing a prototype of an app that will help speed up this process and allow travellers to share some of the information in advance. This is something we are working on to support the member states, although there is no legal requirement for us to do so,” Uku Särekanno said in the interview.

Will the 29 EES countries be forced to use the app?

No, it is understood that Frontex will make the app available on a voluntary basis. Each government will then decide if, when and where to use it, and develop the front-end part based on its own needs.

This point emerged at a meeting of the House of Commons European scrutiny committee, which is carrying out an inquiry on how EES will impact the UK.

What data will be registered via the app?

The Local asked the European Commission about this. A spokesperson however, said the Commission was not “in a position to disclose further information at this stage” but that travellers’ personal data “will be processed in compliance with the high data security and data protection standards set by EU legislation.”

According to the blog by Matthias Monroy, editor of the German civil rights journal Bürgerrechte & Polizei/CILIP the Frontex app will collect passengers’ name, date of birth, passport number, planned destination and length of stay, reason for travelling, the amount of cash they carry, the availability of a credit card and of a travel health insurance. The app could also allow to take facial images. It will then generate a QR code that travellers can present at border control.

This, however, does not change the fact that fingerprints and facial images will have to be registered in front of a guard at the first crossing into the Schengen area.

So given the need to register finger prints and facial images with a border guard, the question is how and if the app will help avoid those border queues?

When is the app going to be available?

The answer to perhaps the most important question is still unclear.

The Commissions spokesperson told The Local that the app “will be made available for Schengen countries as from the Entry/Exit System start of operations.” The planned launch date is currently October 6th, but there have been several delays in the past and may be another one.

The UK parliamentary committee heard that the prototype of the app should have been ready for EU member states in spring. Guy Opperman, Under-Secretary of State at the UK Department for Transport, said the app will not be available for testing until August “at best” and that the app will not be ready in time for October. The committee previously stated that the app might even be delayed until summer 2025.

Frontex’s Särekanno said in his interview: “Our aim is to have it ready by the end of the summer, so it can then be gradually integrated into national systems starting from early autumn”.

READ ALSO: How do the EES passport checks affect the 90-day rule?

Can the system be launched if the app is not ready?

Yes. The European Commission told The Local that “the availability of the mobile application is not a condition for the Entry/Exit System entry into operation or functioning of the system. The app is only a tool for pre-registration of certain types of data and the system can operate without this pre-registration.”

In addition, “the integration of this app at national level is to be decided by each Schengen country on a voluntary basis – as there is no legal obligation to make use of the app.”

And the UK’s transport under secretary Guy Opperman sounded a note of caution saying the app “is not going to be a panacea to fix all problems”.

When the app will be in use, will it be mandatory for travellers?

There is no indication that the app will become mandatory for those non-EU travellers who need to register for EES. But there will probably be advantages in using it, such as getting access to faster lanes.

As a reminder, non-EU citizens who are resident in the EU are excluded from the EES, as are those with dual nationality for a country using EES. Irish nationals are also exempt even though Ireland will not be using EES because it is not in the Schengen area.

Has the app been tested anywhere yet?

Frontex says the prototype of the app will be tested at Stockholm’s Arlanda Airport, in Sweden. Matthias Monroy’s website said it was tested last year at Munich Airport in Germany, as well as in Bulgaria and Gibraltar.

According to the German Federal Police, the blog reports, passengers were satisfied and felt “prepared for border control”.

This article is published in cooperation with Europe Street News.

 
SHOW COMMENTS