France tax for expats:
what you'll pay, what you'll save.

How the treaty works — the short version

Articles 18 and 19 of the 1994 US–France treaty (with the 2004 and 2009 protocols) do something almost no other US treaty does: they give the United States exclusive taxing rights over US-source retirement income — Social Security, 401(k) and IRA distributions, private pensions, and government/military pensions. France must still include the income in your French tax return, but it grants a credit equal to the French tax that would have been due (Article 24). Net effect: zero French income tax on US retirement income.

The income does lift the rate applied to any other French-taxable income you have (taux effectif / exemption with progression). But if US retirement income is all you have, France has no other income to tax at the higher rate. Combined with the quotient familial, a US retiree couple living on Social Security and 401(k) distributions can owe France little or nothing in income tax.

Social Security

Under Article 18, US Social Security benefits paid to a French resident are taxable only in the United States. This is categorically better than most other US treaties (including Portugal), where both countries can tax Social Security and relief comes only through the Foreign Tax Credit.

The US taxes up to 85% of Social Security benefits depending on provisional income. At the top end, the effective federal rate on Social Security is about 22% (85% × the 26% bracket for a typical retiree). France cannot add anything on top of that.

401(k) and Traditional IRA withdrawals

Article 18 covers distributions from qualified plans under Sections 401(a), 403(a), 403(b), and IRAs under Section 408. The treaty gives exclusive taxing rights to the US. Unlike the US–Portugal treaty, there is no ambiguity from the saving clause here — the 2004 protocol specifically clarified the application of these articles to US citizens.

The US taxes these withdrawals as ordinary income at federal rates (up to 37%). France declares the income but grants the credit. If you have no other French-source income, France effectively exempts the entire withdrawal.

Roth IRA — the grey area

If Article 18 applies: the US has exclusive taxing rights, and since the US taxes qualified Roth withdrawals at 0%, neither country taxes the income. If a French tax office reclassifies the income: France may attempt to tax the growth at progressive rates or the 18.6% flat rate on investment income. Keep the 2004 protocol language and the 2020 ministry response in your file, and have a cross-border professional ready to push back.

The timing play is the same as everywhere: complete Roth conversions before establishing French tax residency. Conversions while US-only resident are taxed at US rates; future qualified withdrawals remain tax-free in the US.

Government and military pensions

Article 19 gives the US exclusive taxing rights on government pensions — FERS, CSRS, military retirement pay, and state/local government pensions paid for services to the US government. France cannot tax them. You declare them on your French return with the treaty exemption noted, but no French tax is due.

The quotient familial advantage

Even if the treaty didn't shelter US retirement income, France's quotient familial system would soften the blow. A married couple splits total taxable income across 2 parts; each half is taxed on the bracket scale, and the result is doubled. Effect: a couple with €60,000 of taxable income is taxed as two people with €30,000 each — most of it in the 0% and 11% bands. Add children and each one adds 0.5 parts (the third and beyond add a full part). This is a structural advantage over flat-rate or individual-based tax systems.

Social charges — the 9.1% question

France charges social contributions (CSG 8.3%, CRDS 0.5%, CASA 0.3% — up to 9.1% total) on pension income of tax residents. But US retirement income that France cannot tax under the treaty is also exempt from French social charges. The US–France totalization agreement (since 1988) confirms that you remain covered by US Social Security, not French, so French social contributions do not apply to your US retirement income.

Social charges do apply to French-source income (rental income, French employment income) and to investment income at the higher 18.6% rate. The IRS takes the position that CSG/CRDS are creditable foreign taxes under the treaty — but this is an area where professional advice pays for itself.

Assurance-vie, PEA, and the PFIC trap

The banking problem

Because of FATCA compliance costs, some French banks refuse US-person clients — this is a practical pattern, not a legal rule. BNP Paribas is the most reliably FATCA-compliant option. Expect extra paperwork everywhere and outright refusal at some banks and brokerages. Budget time for it and keep a US account open.

What you still owe the US — the full picture

How the treaty works — Canada keeps taxing rights

Article 18(1) of the Canada–France convention contains an unusual provision: pensions "arising in a Contracting State and paid in respect of past employment" are taxable only in the state in which they arise. For Canadian pensions paid to a French resident, that means Canada — not France — retains exclusive taxation. This is the opposite of most tax treaties, which give the residence state (France) primary taxing rights on private pensions.

France eliminates double taxation under Article 23(2)(a): it includes the Canadian pension income in your French tax base to calculate the applicable marginal rate (taux effectif), then grants a credit equal to the French tax on that income. Net effect: the Canadian pension pushes up the rate on any other French-taxable income, but is not itself taxed in France.

CPP / QPP

CPP and QPP fall under Article 18(1): taxable only in Canada. Canada applies its standard Part XIII non-resident withholding of 25%. There is no treaty-reduced rate — Article 18(1) gives Canada exclusive jurisdiction and Canada's domestic rate applies.

For most CPP recipients, 25% is steep relative to what they'd pay in France's lower brackets. The Section 217 election (below) is the main tool to bring this down.

OAS (Old Age Security)

Same treaty treatment as CPP — taxable only in Canada at 25% withholding. The OAS clawback also applies to non-residents: if your worldwide net income exceeds CAD $93,454 (2025 threshold, adjusted annually), OAS is recovered at 15% of the excess. Full clawback around CAD $152,000 (ages 65–74) or CAD $158,000 (75+). File the OASRI return annually to report worldwide income.

OAS eligibility abroad requires 20+ years of Canadian residence after age 18. Below 20 years, payments may stop after 6 months unless the totalization agreement provides coverage.

RRSP / RRIF withdrawals

RRSP and RRIF payments are "pensions" under Article 18(1): taxable only in Canada. Canadian withholding: 25% on RRSP lump sums, 15% on periodic RRIF payments (reduced rate for periodic payments under Part XIII).

Strategy: convert your RRSP to a RRIF before emigrating. This enables periodic withdrawals at the 15% withholding rate instead of the 25% flat rate on RRSP lump sums.

Section 217 election: non-residents can elect to file a Canadian return and be taxed at graduated resident rates. If your marginal tax as a Canadian resident (including all credits and deductions) would be lower than the flat withholding, the excess is refunded. File Form NR5 in advance to reduce withholding at source. Section 217 returns are due by June 30.

Employer DB pensions

Article 18(1) applies: taxable only in Canada at the 25% Part XIII rate (or graduated rates via Section 217). Note that the Canada–France treaty, unlike several other Canadian treaties, does not give Canada exclusive taxing rights on government employee pensions via a separate article — federal, provincial, and municipal government pensions are treated the same as private pensions under Article 18(1).

TFSA — France doesn't recognise it

You can't make new TFSA contributions as a non-resident (1% per month penalty). Consider liquidating the TFSA before you leave, or at minimum, move it to cash and bonds to minimise the annual French tax on accruing gains.

Departure tax — the hidden bill

Under Section 128.1(4) of the Income Tax Act, when you cease Canadian residency you are deemed to have disposed of all property at fair market value. Capital gains are taxable in Canada.

File Form T1161 (if total FMV exceeds CAD $25,000) and Form T1243. Tax can be deferred via Form T1244, but security may be required.

Quebec–France special relationship

Beyond the Canada–France agreement, Quebec and France have a separate social security entente (signed 2003, in force December 2006, amended 2017). It covers QPP coordination, health and maternity insurance, and allows totalization of contribution periods between France and Quebec specifically. If you contributed to QPP rather than CPP, this entente governs your social security coordination — not the federal Canada–France agreement.

Social security agreement

The bilateral Canada–France Agreement on Social Security came into force in 1981; a revised agreement took effect 1 August 2017. It covers CPP and OAS, allows totalization of contribution periods, and ensures benefit portability. Each country pays benefits based only on contributions to its own system.

UK State Pension

Under Article 18 of the UK–France convention, the UK State Pension is taxable only in France. The UK cannot tax it. Once you obtain an NT (No Tax) code from HMRC, your pension is paid gross with no UK deduction.

For 2026/27, the full new State Pension is £241.30 per week (£12,548/year), a 4.8% increase under the triple lock. This annual uprating is protected for UK pensioners living in France because France is an EU member state and the UK-EU Trade and Cooperation Agreement preserves pension uprating in EU/EEA countries. This is a major advantage over "frozen rate" countries like Australia, Canada, and New Zealand.

France taxes the full amount at progressive rates with the 10% pension deduction. At current exchange rates, the State Pension alone typically falls within the lower brackets (0% and 11%).

Workplace pensions (DB and DC)

Article 18: taxable only in France. Applies to both defined benefit (final salary/career average) and defined contribution schemes. Apply for the NT code to receive payments gross.

SIPP and personal pension drawdown

Article 18 again: SIPP drawdown payments are "pensions and other similar remuneration" — taxable only in France at progressive rates with the 10% deduction. The NT code process is the same.

The 25% tax-free lump sum (PCLS) — take it before you move

While you're still UK tax resident, the PCLS is genuinely tax-free — no UK tax, no French tax (you're not resident yet). Take the 25% before you establish French residency.

Alternative for full encashment: a one-off pension lump sum may qualify for a flat 7.5% rate under Article 163 bis II CGI (after the 10% deduction), plus social charges. This can be significantly better than progressive rates on a large lump sum. Get professional advice on whether your drawdown qualifies.

NHS pensions — not what you'd expect

Despite being a public-sector pension, most NHS pensions are not classified as government service pensions under the treaty. Article 19 (government service) applies only to pensions paid for services to a government body in its administrative capacity. NHS pensions paid by NHSBSA, Capita, or SPPA fall under Article 18 — taxable only in France.

Exception: NHS pensions where the employer was a Local Authority (not an NHS Trust) fall under Article 19 and are taxable only in the UK. This is uncommon.

Government pensions — civil service, military, police

Government pensions taxed only in the UK are still declared on your French return (forms 2047/2042) for the taux effectif — they push up the rate on your other French-taxable income. But no French income tax is due on the pension itself.

If you hold dual UK-French nationality, the government pension exclusion may not apply — the pension may become taxable in both states with credit relief.

Social charges — the big issue, and the S1 exemption

This is the number UK retirees in France need to understand. France charges social contributions on pension income at up to 9.1% (CSG 8.3% + CRDS 0.5% + CASA 0.3%), tiered by income. On top of income tax, this can add significantly to the bill.

But S1 holders are exempt. If you have an S1 form — proving you are affiliated to another state's social security system (the UK's, via your State Pension) — France cannot charge CSG/CRDS on your pension income. This is based on EU Regulation 883/2004, preserved post-Brexit by both the Withdrawal Agreement (pre-2021 movers) and the UK-EU TCA (post-2021 movers). S1 holders pay only the 7.5% solidarity levy (prélèvement de solidarité) on investment income and capital gains — not on pension income.

Getting the NT code — step by step

To stop HMRC deducting tax from your pension at source:

• Complete the DT Individual (France) form (available from HMRC)
• Get it stamped by your local French tax office (centre des finances publiques)
• Submit to HMRC
• Allow 12–16 weeks for processing
• Once issued, your pension provider pays gross — no UK tax deducted

Until the NT code is in place, HMRC deducts tax at the default rate. You can reclaim the overpayment through your UK Self Assessment return or by writing to HMRC. The NT code does not apply to Article 19 government pensions — those remain UK-taxed.

Healthcare — the S1 form post-Brexit

UK State Pension recipients can get an S1 form from NHSBSA, which transfers healthcare cost responsibility from the UK to France. Register the S1 with your local CPAM office and you access France's public healthcare system (Assurance Maladie). Pre-2021 movers are covered under the Withdrawal Agreement; post-2021 movers under the TCA's social security coordination provisions.

The UK Global Health Insurance Card (GHIC) covers emergency treatment during temporary visits back to the UK. Allow 4–12 weeks for NHSBSA to issue the S1.

Age Pension — not exportable

Workaround: some retirees return to Australia periodically to restart the 26-week clock. This is technically permissible but creates tax residency complications in both countries — and Services Australia actively monitors travel patterns. This is not a sustainable long-term strategy.

Superannuation — the gap between Australian and French treatment

This is the biggest issue for Australian retirees. In Australia, super withdrawals after age 60 from a taxed fund are completely tax-free — both lump sums and income streams. France doesn't recognise this.

Under Article 17 of the treaty, France has exclusive taxing rights on private pension income of French residents. France taxes super income streams at progressive rates (up to 45%) with the 10% pension deduction, plus social charges of up to 9.1%. Because Australia charges no tax on the withdrawal, there's no Foreign Tax Credit available to offset the French tax. You go from 0% to up to 54% (income tax plus social charges) simply by changing where you live.

Lump sum option: a one-off super lump sum may qualify for the flat 7.5% rate under Article 163 bis II CGI (after the 10% deduction), plus social charges. This can be dramatically better than progressive rates on a large balance. Professional structuring advice is essential.

Self-managed super funds (SMSF)

If the SMSF fails the residency tests, it loses complying status and is taxed at 45% on all fund assets instead of the concessional 15%. Consider rolling your SMSF into an APRA-regulated retail or industry fund before moving permanently, or appointing an Australian-resident individual trustee with appropriate powers and decision-making authority.

Government and military superannuation

Article 18(2)(a) gives Australia exclusive taxing rights on government pensions (CSS, PSS, military super). France exempts them from French tax but includes the income for the taux effectif. Exception: if you are a French national (and not also an Australian national), the exemption may not apply.

Social charges — full rates, no EU exemption

UK and EU/EEA pensioners with an S1 form are exempt from CSG/CRDS on pension income (the de Ruyter exemption based on EU Regulation 883/2004). Australians don't qualify. You pay the full tiered social charges on all pension income France taxes — up to 9.1% (CSG 8.3% + CRDS 0.5% + CASA 0.3%). On investment income: the full 18.6%. This is a significant cost that doesn't exist in some other European destinations.

CGT on departure — don't forget your Australian home

Australia's CGT Event I1 deems all assets (except "taxable Australian property," primarily real estate) disposed at market value when you cease residency. You can elect to defer, but your assets then become Taxable Australian Property and the 50% CGT discount is apportioned based on days as a resident vs. total ownership.

The main residence exemption trap: from 1 July 2020, non-residents at the time of sale generally lose the main residence CGT exemption. Sell your Australian home before leaving to preserve the full exemption. Narrow life-event exceptions may apply.

Medicare

Medicare eligibility depends on Australian residency. After ceasing residency, eligibility lapses. There is no reciprocal healthcare agreement between Australia and France. You'll need to register with France's Assurance Maladie system (once resident) or arrange private insurance.

The UK State Pension angle

For Australian retirees who also have a UK State Pension: the pension is frozen at the rate when you left the UK if you live in Australia (no uprating agreement). Moving to France unfreezes it — the UK-EU TCA guarantees annual triple-lock uprating for UK pension recipients in EU countries. The difference compounds significantly over a long retirement.

How the treaty works

The South Africa–France convention was signed on 8 November 1993 and has been in force since 1 November 1995. It was modified by the Multilateral Instrument (MLI) from 2024, though the pension articles remain substantively unchanged. Article 18 gives France — as the residence state — taxing rights on private pension income. Article 19 reserves government service pensions for South Africa. France eliminates double taxation under Article 23: it includes SA pension income in the tax base, applies the progressive scale, then grants a credit equal to the French tax attributable to the SA income.

The practical result: if you're French tax resident drawing a private retirement annuity from SA, France taxes the full amount at progressive rates (0–45%) with the 10% pension deduction, plus social charges of up to 9.1%. SA should not tax it — but you need a SARS DTA directive to stop the default PAYE withholding.

GEPF — Government Employees Pension Fund

The GEPF is Africa's largest pension fund, with over 1.2 million active members and assets above ZAR 2.6 trillion. Under Article 19, pensions paid by South Africa for services to the SA government are taxable only in South Africa. France exempts them from income tax but includes the amount for the taux effectif — the income pushes up the rate on your other French-taxable income. You declare the GEPF pension on your French return (forms 2047/2042) with the treaty exemption noted.

GEPF pays pensions to members abroad. Submit periodic life certificates to the GPAA to maintain payments.

Retirement annuities (RAs) and preservation funds

Private retirement annuities, pension preservation funds, and provident preservation funds all fall under Article 18: taxable in France. SA administrators withhold PAYE by default — apply to SARS for a DTA tax directive (form RST01) to reduce or eliminate the withholding. This requires a Non-Resident Tax Status Confirmation Letter from SARS.

France taxes the income at progressive rates with the 10% pension deduction (capped at ~€4,321). The quotient familial applies if you're married — splitting the household income across 2 parts typically reduces the marginal rate significantly.

Living annuities

Living annuity drawdowns are pension income under the treaty — taxable in France. Apply for SARS DTA relief to stop the SA withholding.

Lump sum option: if you take a one-off lump sum from your SA retirement fund, it may qualify for the flat 7.5% rate under Article 163 bis II CGI (after the 10% deduction), plus social charges. This can be significantly better than progressive rates on a large balance. Professional structuring advice is essential.

Social charges — the full rate applies

This is a significant cost that doesn't exist in Portugal or some other European destinations. On €30,000 of pension income, the social charges alone add roughly €2,700 on top of income tax. Factor this into your comparison.

The two-pot system — what changed in September 2024

From 1 September 2024, South Africa's retirement system split into two pots: a savings component (one-third of new contributions, accessible once per tax year) and a retirement component (locked until retirement). Savings-component withdrawals are taxed at your marginal income tax rate in SA — not on the lump sum tables. Whether SARS will grant DTA relief on two-pot withdrawals for non-residents is still an evolving area.

Tax emigration — the 3-year rule

South Africa replaced "financial emigration" with "tax emigration" from March 2021. From 1 September 2024, the old emigration withdrawal category was removed entirely. To access your full retirement fund before retirement age:

• Cease to be a South African tax resident
• Maintain non-resident status for 3 uninterrupted years
• Obtain a Non-Resident Tax Status Confirmation Letter from SARS
• Apply for a tax directive — the withdrawal is taxed on the lump sum table (0–36%)

The 3-year clock starts when SARS recognises your non-residency. If you left SA years ago but never formally ceased tax residency with SARS, the clock hasn't started.

Retirement lump sum tax — what SA takes

These are cumulative lifetime amounts — every lump sum since 1 October 2007 is aggregated before the table is applied. If France has taxing rights under the DTA, France should credit the SA tax paid.

Exchange control — getting money out of SA

South Africa maintains exchange controls via the Reserve Bank. Retirement fund proceeds can be transferred abroad once the tax directive is obtained and tax paid. For other assets, a foreign capital allowance of up to ZAR 10 million per calendar year applies (tax clearance required above ZAR 1 million). The Rand is volatile — ZAR/EUR swings of 10–15% per year are common. Some retirees time large transfers or use forward contracts.

The general framework

France has tax treaties with over 120 countries. The pension provisions vary, but most follow one of two patterns: either the residence state (France) has exclusive taxing rights on private pensions, or the source state retains rights with France granting relief. Government pensions are typically taxed only in the paying state.

Regardless of the treaty, pension income France does tax gets a 10% deduction (capped at approximately €4,321, minimum ~€442) and is then taxed at progressive rates through the quotient familial system. Social charges of up to 9.1% apply unless you're affiliated to another EU/EEA state's social security.

We're adding detailed pension guides for more source countries. If yours isn't covered yet and you'd like specific guidance, get in touch and we'll connect you with a cross-border tax adviser who works with your nationality in France.