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Working in UK/ Living in France

Posted by Nurse Gladys Emanuel - Created: 3 years ago
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10 replies (Showing replies: 1 to 10)

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Posted by walnut72 - 3 years ago

http://www.cleiss.fr/docs/formulaires/e109.html

 

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Posted by Nurse Gladys Emanuel - 3 years ago

Thanks everyone, very helpful advice from you all. X

 

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Posted by DN-434538 - 3 years ago

A very useful web site is Your Europe. This is an EU site and is pretty definitive on such things as cross border working.

Every situation is different though. I found it very difficult, no impossible,  to get any advice from the complicated claims section of HMRC. Notably their address is confidential and they have no public phone number. Correspendence is sent to a totally different department which forwards it to them.

It took them 2 years to get my claim correct.

This site is good.

http://europa.eu/youreurope/citizens/work/work-abroad/cross-border-commuters/index_en.htm

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Posted by countrydweller - 3 years ago

This shows the importance of getting a pro to advise you;in my case the finance dept of the government agency checked with the DWP and HMRC and because I an casual-ie about 5/6 weeks a year they were told not to deduct NIs-if you are permanent/ or do quite a bit then the situation would be different so you need to get proper advice

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Posted by Foxie-986308 - 3 years ago

"The UK will only issue an S1 for a scenario where you are working full time in the UK and spending weekends/holidays in France. " - I don't think it's as simple as that; I think there has to be "substantial" work done in the UK, the question is, how substantial. But the easiest way to find out is to apply for an S1 and see whether you get it or not.

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Posted by Foxie-986308 - 3 years ago

allie-d - I'm not sure what these "social charges" that are being talked about, are. Do you mean cotisations or do you mean CSG? If you mean CSG, that is basically just another tax and it doesn't give you any healthcare entitlement in France. If you mean cotisations and are suggesting that France somehow levies social charges on income earned in the UK - no, that doesn't happen. If you don't work in France then the only way you can join CMU and pay cotisations is if you apply to join and are accepted, and you would then be charged cotisations based on your total worldwide income. 

The situation allie-d seems to be describing is only applicable if you live in France and work for a UK employer, either at home or somewhere else physically within France. In that case, your employer has to pay social charges, but that's because you live in France AND the work is being done on French soil. If the work is carried out in the UK, this doesn't apply. As said, EU law is that workers are subject to the social security of the country in which they work.

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Posted by Foxie-986308 - 3 years ago

Totally agree, DN, BUT, as I understand it, the UK is only obliged to cover you for the exact period when you're working in the UK. The workers S1 isn't open-ended. As soon as you stop work and stop paying NICs you are no longer a cross border worker, you're an inactif resident in France, and the UK is not your competent state. So how does that work for occasional workers - what do you do for healthcare in the periods in between working, and is the UK really going to be prepared to keep issuing S1s for a week here and a week there? I suspect not.

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Posted by allie-d - 3 years ago

Please be careful what advice you take. If you are physically present more in France than UK and do occasional work in the UK then you are liable to pay social charges in France. Countrydweller who is doing similar has replied on this and is doing similar, is giving good advice.

The French social charges are much higher than UK NI contributions. If you are found liable then you need to pay the employer and employee French social charge amounts which is a much bigger amount than the UK NI charges and could leave you out of pocket if unplanned for. France does check into these situations.

The UK will only issue an S1 for a scenario where you are working full time in the UK and spending weekends/holidays in France. 

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Posted by DN-434538 - 3 years ago

I would second Foxie"s post. Social charges should be paid in the UK, if you only work in the UK. If you do any paid  work in France as well as the UK  then social charges would be paid in France.

If youare required to and do  pay social charges in the UK then you are entitled to certain UK benefits, including  depending on pesonal circumstances, tax credits, and child benefit. You should apply for a S1 to go to CPAM and the UK will cover your health costs to the same standard as a French contributor, ie generally 70%. Also your contributions to NI will add to your number of UK pension contribution years. They keep changing the number of contribution years required I think 35 years is currently the optimum.

There are considerable potential benefits in being a cross border worker in the UK whilst resident in France as France raises more revenue by social charges than the UK, but overall it depends much on personal circumstances.

 

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Posted by Foxie-986308 - 3 years ago

If you live in one country and work permanently in another, you are classed as a 'cross border worker', and the arrangement for cross border workers is that they pay social security contributions in the country where they work, and that country funds their healthcare. So if you worked in the UK on a regular ongoing basis, but lived in France, the UK would issue you with a worker's S1 or A1 or whatever form it is, which will entitle you to healthcare in France. But if your work in the UK isn't regular and ongoing then the UK will probably not agree to issue the S1, in which case as countrydweller says you'd have to sort your own healthcare out.

As said, in any case you have to fill in a French tax return, because everybody who lives in France has to do that, and you have to declare your worldwide income which obviously includes what you earn in the UK, but you probably won't have any income tax or charges to pay in France. 

Doing the HMRC residency test would be a good starting point but getting proper advice is a good idea because you don't want to get into a mess with HMRC or the fisc or both, it's stressful. Good luck if you try to get advice from HMRC, you usually have to wait weeks before you can speak to an overseas 'technician'.