Pensions
Receiving pensions paid from the US
Pension direct payments
US citizens who move to France permanently can generally continue to receive their pensions paid from the US. However, the way payments are made, converted into euros and taxed varies depending on the type of pension.
Note too that reporting and compliance matters. Even when a pension is taxable only in one country, it often still needs to be declared in both. US citizens remain subject to US tax filing obligations regardless of residence, while French residents must declare worldwide income. Clear records of pension statements, transfers and exchange rates are essential, particularly where payments are converted or staged over time.
US Social Security pensions
The US Social Security Administration pays benefits to eligible recipients living abroad, including in France, with no requirement to maintain a US address. Payments can be made directly into a US bank account or, in many cases, into a French bank account.
Where payments are made in dollars, the recipient’s bank or payment provider will apply an exchange rate and may charge fees. From a tax perspective, the US–France tax treaty gives France the right to tax US Social Security benefits for residents of France, meaning they are generally taxable in France rather than the US, though they may still need to be declared on a US tax return.
US government pensions (i.e federal, state or military pensions)
These are treated differently – under the tax treaty, these are usually taxable only in the United States, even if the recipient lives in France. Payments are typically made in dollars to a US bank account, and recipients must then arrange conversion into euros if needed.
Because these pensions remain taxable in the US, they are usually exempt from French income tax, although they may still be taken into account when calculating a household’s overall tax rate in France.
Private pensions
These include 401(k) plans, traditional IRAs and employer-sponsored pension schemes, and involve more complexity. Payments are usually made in dollars and paid into a US account, with the retiree responsible for transferring funds to France.
Exchange rates, transfer fees and timing can have a significant impact on the final amount received in euros. Tax treatment depends on the structure of the pension and how withdrawals are taken. In many cases, these pensions are taxable in France under the treaty, but the rules differ for lump sums, regular drawdowns and annuity-style payments.
