Statements such as:
“It won’t be possible to live in France anymore, as we will lose the right, not being in the EU”
“Not being EU citizens, we won’t be able to join the French health system, so moving is no longer possible”
“Now we are leaving the EU, the tax situation between the UK and France, means everything is very uncertain”.
The problem is that, as common as these and similar statements were and are, they are not anchored in reality.
There is a lot we do not know about Brexit, much of it political and economic, but regarding our personal situation, however, what do we know? I will answer the questions above in reverse order:
There is a tax treaty between the UK and France (nothing to do with the EU)
When it comes to the France/UK tax situation we refer to both the income tax treaty and the succession treaty between the two countries. These are bilateral agreements with absolutely nothing to do with the EU.
So, we can continue to plan with certainty.
We know how UK rental income, civil service income etc. will be treated in France as there is already a cast-iron agreement, which has no relation to the EU.
We also know how UK property is dealt with for succession and inheritance in France, because the succession treaty will not change as it is unrelated to the EU.
All French residents (even non-EU) have the right to join the French healthcare system
From January 1 2016 the previous system of healthcare, known as the Couverture Universelle Maladie (CMU), was abolished and a new system, Protection Universelle Maladie (Puma), was established. Puma grants automatic and continuous right to healthcare in France to those legally resident in the country, no matter what nationality.
The residency requirements state that, to be entitled to healthcare, you must live in France in a way deemed ‘stable et régulière’. For British citizens moving to France on a permanent basis, this can be achieved quite easily. The law requires you must have been resident for a minimum of three months and then continue to live in France for at least six months of the year.
The good news is that access to the French health system is in no doubt. The issue is that you may have to pay for access.
If you access healthcare by making contributions, this would be 8% of the household “taxable” income, currently above €9,654.
There are other routes, especially for those that have an activity, even earning very small revenues. In fact, a low income is desirable as things can be kept very simple indeed.
The point is there are solutions if the S1 European healthcare entitlement certificate is not an option. We advise the S1 be ignored. It is uncertain, we cannot plan on it; so we look only at options that are certain and move on this basis.
Residence is high probability… as long as you are not a liability
I moved to France before the EU gave UK citizens the automatic right to live and work in Europe. I was doing the same job then as now, helping Britons move to France. Moving, at that time, was no problem for me or my clients.
The rules on being permitted to live in France are relatively simple:
- That you are not a danger to society, thus have no criminal record n That you can easily support yourself financially and so will not be a burden on the state A non-EU citizen is required to apply for a residency permit (carte de séjour), with evidence they have satisfied these criteria. The authorities may refuse an application by a non-EU national, but this is rare where the above criteria are met.
There was no visa requirement back then, and one could argue this is an unknown, but there is no such thing as an EU visa (though there is a Schengen Visa), so France would need to impose a visa requirement on the UK, which is unlikely, given the number of French living in the UK.
This article is dealing only with certainty, so even if a visa was required, there are many people living in France who cope just fine. Again, as long as they are not a burden on the state, and not a danger, applications are rarely declined.
Many people we speak to have been waiting for years or even their whole lives to realise their dream of living in France. It has, and always will, provide challenges; changing countries is never easy, so it needs to be intelligently considered and planned so you can spend your time focusing on what you moved to France for... making the most of life!