Tax When You Move From the UK to France: Residence, HMRC and the Treaty (2026)
By Aurelio Maurici Co-Founder, Master of Business Law, Aix-Marseille Université III
Published

In this article
- How France decides you are a tax resident
- How the UK decides you have left
- Split-year treatment
- Check your status, then recheck it
- Telling HMRC you are leaving
- UK income you keep after you leave
- Letting out a UK home
- What the UK-France treaty does
- Where you are resident
- Which country may tax which income
- How double tax is relieved
- Your first French tax return
- Who to ask
- Related guides for British readers
- FAQ
Moving from the UK to France changes which tax authority you answer to, and for a while it can mean both. This guide explains how each country decides where you are resident, what you tell HMRC when you leave, what the UK-France treaty says, and how your first year of French returns works. It describes rules. It does not work out your own position, and the people who decide that are named at the end.
For the wider move, see moving to France from the UK.
How France decides you are a tax resident
French tax residence is written in article 4 B of the Code général des impôts. Légifrance shows that a person has their tax domicile in France if they meet any one of three criteria:
- Their home or main place of residence is in France.
- They carry on a professional activity in France, employed or self-employed, unless it is only incidental.
- The centre of their economic interests is in France.
The same article extends French tax domicile to certain civil servants posted abroad, which will rarely apply to you.
The criteria are alternatives. Meeting one is enough. The French tax administration’s resident page explains them in plain terms. You have your home in France if you live there habitually and permanently. The professional test looks at whether you work mainly in France. The economic test is linked on that page to French-source income being greater than foreign-source income.
A person who meets a criterion is still not treated as tax-domiciled in France if a tax treaty treats them as non-resident there. That is where the UK-France convention comes in, covered below.
Once you are a French tax resident, the same page says you are taxable on income from French and foreign sources, subject to international treaties. That is the big change for many British arrivals: income that stays in the UK, such as a pension or rent from a UK flat, can come into the French return.
How the UK decides you have left
The UK uses the Statutory Residence Test. GOV.UK says you are UK resident for a tax year (6 April to 5 April) only if you meet one or more of the automatic UK tests or the sufficient ties test, and none of the automatic overseas tests. Otherwise you are non-resident.
The automatic UK tests include spending 183 or more days in the UK in the tax year. The automatic overseas tests include spending fewer than 16 days in the UK, or fewer than 46 if you were not UK resident in the previous 3 tax years, and working full time abroad with fewer than 91 days in the UK. The sufficient ties test depends on how many days you spend in the UK and which ties you keep, such as work or family. GOV.UK sends you to HMRC’s full guidance on the test for the detail.
Split-year treatment
The year you move can be divided into a part when you were UK resident and a part when you were not. GOV.UK calls this split-year treatment. It does not apply automatically, and GOV.UK says you will not qualify if you live abroad for less than a full tax year before returning to the UK. HMRC’s guidance lists the other conditions.
Check your status, then recheck it
GOV.UK links an online residence status checker and notes that your status can change from year to year. Buying or selling a UK home, changing jobs and family moves are among the things it says to recheck after.
Telling HMRC you are leaving
There are two routes on GOV.UK.
- Form P85. The P85 guidance is for people who lived and worked in the UK, have left and may not be coming back, and work abroad full time for at least one full tax year. You use it to tell HMRC you have left or are leaving and to claim back tax from UK employment. HMRC asks whether you have a home in the UK, whether you work full time outside the UK, whether you still have salary paid in the UK and whether you will spend time in the UK over the next 3 years.
- Self Assessment. The same page says you do not need the form if you are sending a Self Assessment return for the tax year you leave the UK.
If you are retired and not employed, P85 may simply not fit your situation. Which route applies to you is a question for HMRC or your adviser.
UK income you keep after you leave
GOV.UK says that if you live abroad you usually need to send a Self Assessment return when you rent out UK property, work for yourself in the UK, have taxable savings interest from UK banks or building societies, have other untaxed UK income, or have a pension outside the UK and were UK resident in one of the previous 5 tax years. It also says non-residents cannot use HMRC’s online services for this and that paper returns are due by 31 October.
Letting out a UK home
GOV.UK’s guidance on rent for landlords abroad says a landlord who lives abroad for more than 6 months of the year must pay tax on UK rental income, collected through the Non-resident Landlord Scheme. Letting agents must operate it. Tenants must deduct tax if they pay more than £100 a week in rent. The tax is the basic rate of Income Tax on the net rent, and payments are due within 30 days after each tax quarter ends. Tax is not deducted if HMRC has told the landlord in writing that the rent can be received with no tax deducted.
If you are thinking of selling instead, see selling UK property when moving to France.
What the UK-France treaty does
The convention in force dates from 2008 and has been modified by the Multilateral Instrument. GOV.UK’s treaty page says it entered into force on 18 December 2009, and lists the 2008 text and a synthesised text that includes the modifications.
Where you are resident
Article 4 of the convention text settles the case where both countries treat you as resident. It applies these tests in order:
- Where you have a permanent home available to you. If you have one in both, the country with which your personal and economic ties are closer.
- Where you habitually live.
- Your nationality.
- If that still does not settle it, the two tax authorities decide by agreement.
Which country may tax which income
The article numbers below are those of the convention text. Read the whole article before relying on a summary.
| Income | What the convention says |
|---|---|
| Income from property (Article 6) | May be taxed in the country where the property is |
| Dividends (Article 11) | The recipient’s country may tax; the paying country may also tax, capped at 15% of the gross amount |
| Interest (Article 12) | Taxable only in the recipient’s country of residence, unless connected with a permanent establishment in the other country |
| Employment (Article 15) | Generally taxed in the country of residence, unless the work is done in the other country |
| Pensions for past employment (Article 18) | Taxable only in the country where the recipient is resident |
| Government service (Article 19) | Generally taxed only by the paying country, with an exception for someone who is resident and a national of the other country |
Source: GOV.UK, 2008 UK and France Double Taxation Convention (in force), Articles 6, 11, 12, 15, 18 and 19.
Some points sit outside this table: gains on immovable property may be taxed where the property is (Article 14), and the treaty text on the State Pension and on pension lump sums should be read in full. For the State Pension specifically, see the UK State Pension in France.
How double tax is relieved
Article 24 relieves double taxation by credit. France gives a credit for UK tax on income that is taxable in the UK, capped at the French tax attributable to that income. The UK gives a credit for French tax against UK tax on the same profits, subject to UK law. The text provides no exemption method for either country.
GOV.UK adds that if a double taxation agreement applies, you can claim UK tax relief to avoid paying twice, and that you do not need to report income to HMRC if you have already claimed such relief. To prove UK residence to a foreign tax authority, HMRC offers a certificate of residence for people entitled to treaty benefits.
Your first French tax return
The French tax administration’s page for people arriving in France (impots.gouv.fr) gives this timetable.
- You arrive in year N. You file in year N+1.
- If you had no French tax obligations before, you file return form 2042 with the tax office (service des impôts des particuliers) for your new home, and you declare all the income you received since your arrival.
- If you were a non-resident with French-source income, that income before your arrival goes on form 2042-NR and the income after goes on form 2042.
- Filing is online where possible. The page says paper is needed if you cannot file online and you are declaring in France for the first time.
The deadlines change each year. For the 2026 return on 2025 income, impots.gouv.fr gives 21 May online for departments 01 to 19 and non-residents, 28 May for departments 20 to 54, and 4 June for departments 55 to 974 and 976. Paper returns must arrive by 19 May 2026. A balance under €300 is debited in one payment in September, and a larger one in four monthly debits from September to December. The page also says you must keep filing every year. Check the dates for the year you arrive.
Who to ask
HMRC and the French tax office (service des impôts des particuliers) decide how the rules apply to you, and the treaty can override the domestic tests. GOV.UK says an accountant or tax adviser may be able to help, and that you must authorise them to act for you with HMRC. Pick an adviser who works on both sides of the Channel.
Related guides for British readers
- Our guide to opening a French bank account as a UK citizen covers what a French bank asks a British resident for, the proof-of-address loop, the right to an account if a bank refuses, and why your UK accounts must be declared.
- Our guide to sending money from the UK to France covers comparing providers, checking FCA status, the French form 3916 for UK accounts and source-of-funds questions.
FAQ
Can I be tax resident in both the UK and France?
Yes, under each country’s domestic rules. The treaty then decides: permanent home first, then where you habitually live, then nationality, then agreement between the authorities.
Do I have to fill in form P85?
It is for people who lived and worked in the UK and are claiming back tax from UK employment. GOV.UK says you do not need it if you are sending a Self Assessment return for the year you leave.
Do I still file in the UK after I move?
GOV.UK says you usually do if you still rent out UK property, work for yourself in the UK, have taxable UK savings interest or other untaxed UK income. Check your position with HMRC.
Does France tax my UK pension?
Under Article 18 of the convention, pensions for past employment are taxable only in the country where you are resident. Government service pensions follow Article 19. Read both before relying on this.
When is my first French return due?
In the year after you arrive. It covers income from your arrival date to 31 December. The exact dates are published each year by the French tax administration.
Does the UK State Pension change anything?
See the UK State Pension in France and National Insurance when living in France.
Written by
Aurelio Maurici
Co-Founder, EasyFranceNow
Aurelio Maurici is a French entrepreneur and co-founder of EasyFranceNow. His work focuses on the intersection of French administration, banking constraints affecting U.S. nationals, tax residency and cross-border reporting, healthcare enrollment, and the procedural realities Americans encounter while settling in France.



