UK nationals in France: after Brexit, the map changed

The UK–France route is one of the oldest expatriate paths in Europe, and Brexit changed its financial rules substantially. Much of what worked in 2015 no longer does; good replacements exist, but they are French, not British.

Brexit did not change how France taxes British residents. It changed what British institutions are allowed to do for them. UK wrappers kept their British treatment and lost their European passport, so a portfolio that worked across the Channel in 2015 may now be fully taxable in France, unreported by its provider, or simply orphaned by an adviser who can no longer serve EU residents. Rebuilding it is entirely possible, using French and Luxembourg structures in place of British ones.

What stopped working

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.

What replaces it

The French assurance-vie does most of what an ISA did — tax-efficient compounding, an annual allowance on withdrawals after eight years — and adds an estate-planning layer ISAs never had. UK pensions remain workable from France under the treaty: taxation generally follows residence for most private pensions, and drawdown timing can be planned around French rules. The France–UK inheritance-tax convention of 21 June 1963 is still in force, but it was written for the old UK estate duty and for a domicile-based system: it was not designed to arbitrate the residence-based inheritance tax the UK moved to in April 2025, and its interaction with that reform is still settling. British estates here are planned with that uncertainty on the table, not around it.

Pension transfers are a regulated, one-way decision — the firm analyses them case by case, and recommends against more often than for. A confident, one-size-fits-all answer on QROPS is a sales pitch, not an analysis.

The state pension no longer up-rates automatically for new arrivals

Under the Withdrawal Agreement, British nationals who were already resident in the EU by the end of the transition period keep their UK state pension's annual uprating for as long as they remain resident there, as if Brexit had not happened at all. Anyone who has moved to France since does not benefit from that protection under current rules: the pension is paid, but without the guarantee that it rises each year the way it would for someone who stayed in the UK. It is a narrower, quieter change than the ISA and adviser questions above, and one new arrivals rarely check before they move. Scheme-by-scheme transfer analysis — including where a QROPS still makes sense and where it does not — is covered in UK pensions and SIPPs once you are tax resident in France.

Frequently asked questions

Is my ISA tax-free in France?

No. France does not recognise the ISA wrapper: 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?

Under the UK–France treaty, most private pensions and drawdown income are taxable in France (with specific rules for government-service pensions). Lump sums are the point to settle before you act, not after: the UK's tax-free pension commencement lump sum has no equivalent in French law, and how the 2008 treaty allocates the right to tax a lump sum paid by a UK scheme to a French resident is read on the treaty text, file by file, before any drawdown instruction is given. A figure quoted without reading those documents first is not an answer, only a guess. Planning the drawdown sequence before it starts is what the interaction rewards.

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?

Not under current rules. That protection applies to British nationals who were already resident in the EU by the end of the Brexit transition period. Moving to France today still gives you the pension itself, but without the same guarantee of an annual increase — a distinction worth checking before treating the state pension as a fixed, rising part of a retirement budget.

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

Sometimes, and the analysis has to be done scheme by scheme — currency, drawdown flexibility, and how each option is treated for French succession purposes all point in different directions depending on the pension and the person. A generic recommendation on this question is worth exactly what it costs.

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, Singapore, Hong Kong, Bangkok, Shanghai and Dubai.

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Written by Stéphane Molère, Président d'Éthique et Patrimoine — page last reviewed on 2026-08-27 — rules quoted are those in force at that date.