Last Updated on 7th February 2026
France has long been an attractive location for British expats, and double tax treaties between the UK and France provide assurance that foreign nationals won’t be subject to double taxation in both countries – provided the treaties are applied and claimed correctly.
These rules are significant for expats, as they determine how and where individuals are taxed, where they are considered tax residents, and, ultimately, how great their tax exposure is.
Chase Buchanan’s French team has compiled some common queries to help you understand how expat tax treaties work.
What Is the Tax Treaty Between France and the UK?
A double tax treaty is a bilateral agreement in which each tax authority formally commits to preventing citizens of either country from being taxed twice.
It determines which jurisdiction has the right to tax an individual’s income and provides rules for the way foreign nationals can claim tax credits and other reliefs.
How Do French Tax Treaties Decide if I Am a UK or French Tax Resident?
Tax residency is a key aspect of tax treaties, and the agreement sets criteria that tax authorities use to determine where a person is resident for tax purposes. These include factors like the location of their:
- Primary residential home
- Spouse, partner or children
- Economic interests such as assets, businesses and employment
The treaty also looks at how long a foreign national spends in each country per year and provides tiebreakers that offer a definitive decision when there is uncertainty about a person’s correct tax residency status.
Does the Tax Treaty Between the UK and France Cover Inheritance Tax?
It does, yes, and there is, in fact, a separate tax treaty that specifically covers inheritance. Its purpose is to ensure estates aren’t taxed twice, and applies rules depending on the individual’s residency position, domiciliary status and the location of their assets.
French succession laws do, though, remain applicable to assets held in France, including forced heirship rules, which is why estate planning is so important for UK expats living there.
Are UK State Pensions Taxable Under French Tax Treaties?
Yes, if you’re a French tax resident and you receive a pension, either from a UK fund or elsewhere, this will be taxable in France at the prevailing rates. Depending on your circumstances, pension income may also be subject to social charges.
The State Pension is taxed in the same way as any other pension scheme, such as a workplace pension fund. However, UK government pensions remain taxable in the UK but are still reportable in France.
Will I Need to Register as a French Resident to Claim Tax Treaty Provisions?
No, there isn’t a system whereby foreign national residents living in France need to register to be able to claim against double tax treaties. That said, anyone submitting French tax returns will need to be a recognised tax resident with a numéro fiscal – the equivalent of a Unique Taxpayer Reference in the UK.
Are Expat Tax Treaties in France Applied Automatically?
Not necessarily, and it’s a frequent mistake to assume tax reliefs within the UK-France treaty will be applied to your tax calculations. Although the Public Finances Directorate General (DGFiP) sometimes applies treaty relief to submitted returns, this is less likely in the UK.
Instead, individuals will usually need to actively claim benefits and tax reliefs through HMRC, especially those applied to pension or investment earnings, and submit a formal request to ensure that tax doesn’t continue to be deducted in the UK.
Is it Possible to Be a Tax Resident in Both France and Britain at the Same Time?
Theoretically, yes, a person could meet the criteria and be technically a tax resident in two places. This is one of the important roles of a double tax treaty, as it sets out tiebreakers to help tax authorities determine where an individual is a tax resident.
In most cases, expats will still need to file the relevant returns and declarations. As long as they apply the treaty rules correctly, they won’t pay tax twice and will have a credit issued against one liability.
How Do French Tax Treaties Apply to UK Investment Funds?
The double tax treaty determines where investment income is taxed, whether dividends, interest, the proceeds from the sale of shares, or another form of payout. It also ensures that investment tax isn’t duplicated in both the UK and France.
However, French tax rules apply to UK-based investment funds if the holder is a French tax resident, because the individual will be subject to French taxation on their worldwide income and assets.
The specific treatment of investment income will depend on the nature of the fund and its earnings, and the treaty doesn’t override how those assets are classified and assessed for tax.
What Mistakes Should I Avoid When Applying UK-France Tax Treaties?
Double tax treaties cover a wide range of areas, taxable events, and rules, and the biggest error is when expats plan a relocation without realising the many contrasts between UK and French taxation, or without considering the need to plan strategically to protect their wealth.
Examples include:
- Making assumptions about where an expat will be considered a tax resident
- Not realising that tax-efficient UK-based products, like ISAs, don’t offer the same tax benefits in France
- Failing to declare income or assets held in the UK on a French tax return
- Thinking that provisions in double tax treaties are applied automatically
Another key issue is making important financial decisions without professional input and speaking to a financial adviser or wealth manager only after problems or unexpected tax liabilities have already occurred.
Have UK-France Double Tax Treaties Changed Post-Brexit?
No, Brexit meant that the UK left the European Union in 2020. Although this has had sweeping impacts on British nationals’ ability to travel to the EU without a visa and on the types of permits expats need to apply for, it hasn’t affected individual tax treaties between the UK and EU member states.
The UK-France current tax treaty took effect from 2010 and pre-dates Brexit. France has among the most tax treaties of any country, with an estimated 120 bilateral agreements in place.
Further Information and Insight Into French Double Tax Treaties
If you have any remaining questions about double tax treaties in France, how they apply to you, or more specific elements of French residency and French taxation, you are welcome to contact the Chase Buchanan Private Wealth Management local French team, who will be happy to assist.
Alternatively, there are many downloadable, complimentary guides and articles in our Knowledge section, with a search function to help you find the information you require.
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*Information correct as at February 2026
