Financial planning in France for UK nationals after Brexit

Living in France with assets in the UK calls for a coordinated review of your accounts, pensions and family arrangements. We help you identify the decisions that involve both countries, from an ISA you have retained to the way your estate is organised. The right starting point is your situation today, whether you are preparing to move or are already here.

Brexit changed the cross-border permissions on which some UK providers relied. It did not make every existing account unusable. Ask each bank, platform and adviser what it can still do for a French resident, then review the French tax and reporting treatment. Retaining an account and replacing it with a French or Luxembourg arrangement are options to compare, not an automatic sequence.

In short

For a UK national in France, the planning review covers the accounts and investments held in the UK, each pension scheme with the withdrawals or transfers considered, and the ownership details, wills and beneficiary arrangements relevant to both countries.
France has never recognised the ISA tax shelter: interest, dividends and gains inside it are taxable in France like an ordinary account once you are French-resident, and it must be reported under Article 1649 A of the French tax code.
Under article 18 of the France–UK convention of 19 June 2008, a pension paid for past employment is taxable only in the state of residence; article 19 reserves government-service pensions to the paying state, with a nationality exception.
GOV.UK states that the UK State Pension rises each year for people living in the European Economic Area, including France, whatever their nationality and whenever they moved; the France–UK treaty decides where it is taxed.

Bring your UK and French arrangements into one review

An account, a pension and an inheritance question do not follow the same rules. We separate those questions, identify the documents needed and organise the points to be reviewed with the appropriate professionals.

Accounts and investments: list what you hold in the UK and any restrictions your providers have communicated.
Pensions: identify each scheme and the withdrawals or transfers you are considering.
Family and property: gather the ownership details, wills and beneficiary arrangements relevant to both countries.
Next steps: record the decisions, the person responsible for each question and the information still needed.

What to check with UK providers

ISAs: never recognised by France, before Brexit or since — interest, dividends and gains inside an ISA are taxable in France like any ordinary account the day you become French-resident, and the account itself must be reported under Article 1649 A of the French tax code;
UK financial advisers and platforms: many lost the right to serve EU residents, leaving accounts frozen or clients unadvised;
pension flexibility: transfer options narrowed and the cross-border rules hardened — pension decisions now deserve treaty reading before any move.

Choosing what to keep or change

An ISA, a pension and an assurance-vie serve different purposes. Compare any proposed replacement on fees, investments, access and tax in both countries. UK pensions need a scheme-by-scheme treaty review, though the starting point is settled: under article 18 of the France–UK convention of 19 June 2008, pensions and similar remuneration paid for past employment are taxable only in the state of residence, so in France for a French resident, while article 19 reserves government-service pensions to the paying state unless you are a resident and a national of the other state without also holding the nationality of the first.

For succession tax, examine the France–UK convention of 21 June 1963 alongside the UK rules applying since April 2025; the change to domestic rules is not a reason to assume the convention has ceased to operate.

Before transferring a UK pension, check which guarantees you would lose and whether regulated UK advice is required. These guarantees, which the rules call safeguarded benefits, can include a final salary pension, a guaranteed minimum pension or a guaranteed annuity rate.

For certain transfers, conversions or lump-sum withdrawals (taking money as cash instead of regular income), the scheme must check that you have received appropriate independent advice: Pension Schemes Act 2015, section 48 ↗. This statutory check does not apply where the cash-equivalent value of your safeguarded benefits under the scheme is £30,000 or less: Transitional Provisions and Appropriate Independent Advice Regulations 2015, regulation 5 ↗.

Where required, that advice must come from an adviser with the relevant UK permission, and it is separate from the review we carry out.

A QROPS answer that holds up is built on your own facts: the type of scheme and whether it carries guarantees you would give up, the currency you will spend in, the charges of the receiving scheme against those of the one you leave, the treatment of each payment under the treaty applicable to the scheme’s country, what happens to the pot on death under French succession rules, and the UK tax charge that can apply to the transfer itself.

The State Pension, and the annual increase for residents of France

The UK State Pension is increased each year for people living in France. GOV.UK sets out four situations in which the yearly increase applies: the European Economic Area, Gibraltar, Switzerland, and countries that have a social security agreement with the United Kingdom.

Canada and New Zealand are named exceptions: they have such an agreement, and the pension is nonetheless frozen at its starting rate there. GOV.UK also states that the rules apply regardless of nationality and regardless of when you moved, so arriving after the end of the Brexit transition period does not put you on a frozen rate.

If you may later move on from France, the rule to check is that of the next country rather than this one. What you do still have to settle is where the pension is taxed, which the France–UK treaty decides, and how it is paid into a French account. Scheme-by-scheme transfer analysis, including where a QROPS still makes sense and where it does not, is covered in UK pensions and SIPPs for French tax residents.

Who will work with you?

Véronique Yang is a private wealth manager based in Paris, and she follows foreign nationals settling in France: tax residence, the first returns, and the treatment of the accounts, pensions and policies you keep in the United Kingdom. James Meyer, based in London, follows French nationals living in the United Kingdom — the mirror situation, and the reason the same treaty questions are read from both sides of the file.

What stays outside the firm is the advice a UK-authorised firm alone may give on a transfer out of a scheme carrying safeguarded benefits. Cross-border wealth advisers in France sets out the scope of the work and who carries it out.

References cited

GOV.UK — State Pension if you retire abroad: rates of State Pension · GOV.UK — Benefits and pensions for UK nationals in the EEA or Switzerland

Frequently asked questions

Is my ISA tax-free in France?

No. France does not recognise the tax shelter an ISA provides: interest, dividends and gains inside it are taxable in France once you are French-resident. Keeping the ISA may still make sense in some situations, but its tax advantage does not travel.

How is my UK pension taxed if I live in France?

Classify the pension and the payment under the France–UK treaty. A private pension paid for past employment is taxable only in your state of residence under article 18; a government-service pension stays with the paying state under article 19, unless you are a resident and a national of the other state without also holding the first state’s nationality. A UK tax-free lump-sum label does not automatically carry over to France. Obtain the calculation and any provider forms before instructing the withdrawal.

Does French forced heirship apply to my UK will?

As a French resident, French succession law, including the children’s reserved share, applies by default to your estate. An election for the law of your nationality under the EU Succession Regulation may be available, with limits that have evolved in recent years; it needs to be weighed, drafted and kept under review.

Will my UK state pension keep rising every year if I move to France now?

Yes. GOV.UK confirms that the State Pension rises each year for people living in the European Economic Area, which includes France, and that this applies regardless of nationality and regardless of when you moved. The date of your move does not change it. The same yearly increase applies in Gibraltar, in Switzerland, and in countries that have a social security agreement with the United Kingdom — with Canada and New Zealand as named exceptions, where the pension stays at its starting rate despite such an agreement. Anywhere else, it is frozen at the rate you first received. The open questions for a move to France are which country taxes the pension under the France–UK treaty, and how you arrange for it to be paid.

Should I transfer my UK pension to a QROPS after Brexit?

Compare keeping the existing scheme with the specific transfer proposal. Include guarantees lost, charges, currency, access, death benefits and any transfer tax. Brexit alone is not a reason to transfer, and the receiving scheme’s status must be checked.

ÉTHIQUE ET PATRIMOINE, a French simplified joint-stock company (SAS), registered office at 41 rue Saint-Ferdinand, 75017 Paris, France, Paris Trade Register no. 803 414 796, VAT no. FR 40 803 414 796, registered with ORIAS under number no. 24001817 (www.orias.fr) — Financial investment adviser (CIF) no. 18002418, member of ANACOFI-CIF, a professional association approved by the Autorité des marchés financiers, and Anacofi-Courtage for its brokerage activity. Presence: Paris, Montpellier, London, Singapore, Hong Kong, Bangkok, Shanghai and Dubai.

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