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PENSIONS

Pensions: What should I expect if I worked in both France and a non-EU country?

For people who have worked both in France and in another non-EU country, it can be challenging to decipher what to expect from your pension.

Pensions: What should I expect if I worked in both France and a non-EU country?
(Photo by JOEL SAGET / AFP)

For those who move to France when they are of working age, it’s common to have worked – and contributed to a pension – in several countries. So what happens to combining all those pensions when you come to retire?

The short answer is that periods of employment outside France can be combined with years worked in France to boost or qualify for the French state pension – but it depends on which country you have worked in, whether that country is in the EU/EEA or whether that country has a social security agreement with France.

READ MORE: EXPLAINED: The website to help you calculate your French pension

The EU and EEA countries, and Switzerland have social security coordination which means that pensions can be easily combined.

For those who worked in France and another non-EU/EEA country (eg the USA, Australia or Canada) – the pension calculation is a bit different.

For Brits it depends on when you arrived – those who lived in France before December 31st 2020 (ie those covered by the Withdrawal Agreement) benefit from the same arrangements as EU/EEA countries. Those who arrived after that date fall under the general rules for non-EU countries.

The key is whether the countries you worked in – listed here – also have social security agreements with France that will allow you to combine work periods.

A calculation will be done between the two countries to determine the amount of the French pension you qualify for and the amount of the pension you qualify for from your home country. Then, you will receive these payments separately. 

A few countries – listed here – have agreements with France for self-employed workers.

READ MORE: Ask the experts: What do Americans in France need to know about investments and pensions?

The situation for Americans

Americans living and working in France benefit from the Franco-American Social Security Agreement (SSA). Essentially, this allows Americans who have worked in France to have their pension calculated on a pro rata basis. The agreement specifies that this calculation will be done by “multiplying the theoretical amount by the ratio of the periods of coverage under French laws to the total periods in both countries.

Take the example that France’s state agency Assurance Rétraite wrote for “Michael”, born in 1955, who worked in both the US and France to demonstrate how the SSA is put into action.

To retire by French standards, Michael would need 166 quarters to have a full rate. If he has contributed 150 trimestres in France, and 18 in the United States, that means that once he has reached the age of 62, he can apply for his French pension (as he has a total of 168 trimestres worked between the two countries).

READ MORE: Reader Question: How long do I have to work to qualify for a French pension?

The calculation would be as follows: 

Screenshot by the Local from AssuranceRetraite.FR

In English, the formula to calculate the amount of Michael’s French pension would be: Michael’s average annual salary X The full pension rate of 50 percent X 150 (quarters contributed in France) / 166 (Total quarters worked).

The reason the calculation uses 166 instead of 168 quarters is that the Franco-American agreement states that to “avoid an excessive pro rata reduction for workers with many years of coverage under the US and French systems, the denominator of the ratio is limited to the number of quarters of coverage required for a full old-age pension under French laws.”

Essentially, the agreement allows you to combine years of work in France and the United States, which can count toward your American retirement too.

According to Tax Partner, Jonathan Hadida, who works for Hadida Tax Advisors, a company that specialises in tax consulting and helping Americans living in France to be tax compliant in both countries, Americans looking for assistance with their social security should contact the US Embassy in Dublin, which has a dedicated team to assist with social security questions for Americans abroad.

For Americans looking for more information about saving money and investing while in France, as well as the rules for continuing to access private pension plans, such as a 401K or IRA, you can learn more HERE

The situation for UK nationals

For Brits who have moved to France post-Brexit, as of 2023, it was still not clear whether an updated social security agreement between the two countries had been put into place.

Those who moved prior to Brexit – as mentioned above – continue to have their pension contributions made in France calculated in the same way that EU/EEA countries have theirs calculated. You can learn more about this HERE.

Keep in mind that you may need a bank account in the United Kingdom to access your UK pension. This has been an issue for some Brits living in France. 

READ MORE: Brexit: How to avoid bank account closures by opening a French bank account

The situation for Australians

If you are Australian, you should beware the ‘pensions trap’ resulting from the lack of an international social security agreement.

The lack of a bilateral social security agreement has made it so that many Australians of retirement age who live in France cannot claim an Australian old- age pension, even if they have spent their lives working and paying taxes in Australia. You can find the full details here.

READ MORE: Australians planning to retire to France warned over little-known pension trap

A final key point is for foreigners who receive a state pension from their home country, you may need to have access to a bank account in that country to collect the funds. 

This article is a general view of the pension system and does not constitute individual financial advice. If you are are unsure about your pension rights, seek independent financial advice.

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VISAS

‘Be ready to wait’: Your tips for getting a French visa post-Brexit

Now that Britain is out of the EU, just how much harder is the process of moving to France from the UK after Brexit? British readers share their experiences of applying for visas as 'third country nationals’.

'Be ready to wait': Your tips for getting a French visa post-Brexit

Whether you’re moving to France to live, or you’re a second-home owner wanting to spend more than 90 days out of every 180 in France, if you’re British you will now need a visa.

You can find more on how to apply for a visa, and how to understand what type of visa you need, in our visa section HERE.

But how these systems work in practice is not always the same as the theory.

To learn more about the process of getting a visa as a UK national, The Local asked British readers for their experiences of going through the system.

The consensus among respondents was that the whole thing was bureaucratic, though there were notable differences in experiences that ranged from the “easy” to the “complicated” and “time-consuming”, while the advice for future applicants was, routinely, have all your paperwork ready – and be prepared for a lengthy wait at one of the UK’s TLS centres

Appointments

Like most visas, French visas for UK nationals must be applied for before you leave home. You can find a full explanation of the process here, but the basic outline is that you apply for the visa online, and then have an in-person appointment in the UK in order to present your paperwork. 

Sue Clarke told us: “As long as you get all your paperwork together correctly and in the right order, the time it takes to receive your passport back with the visa in it once TLS has sent it off is only a few days.

“TLS – the centre which works on behalf of the French Embassy to collate your application – is so very busy,” she added. “That part of the process took hours even when you have an appointment.”

READ ALSO EXPLAINED: What type of French visa do you need?

“The visa process itself was fairly well run, and a decision for the initial visa was quick,” wrote Ian Sheppard, who successfully applied for a visa in July 2022. 

“Although getting the follow up residence permit was a pain, [and] took longer than expected, and there was little to no communication with severely limited ways to get in touch about the application.”

Sheppard thought that, biometrics apart, the process could have taken place online, and wondered whether the follow-up residence permit application could be more closely linked to the initial visa application, “rather than effectively submitting the same application twice”.

Georgina Ann Jolliffe described the process as “stressful”. 

“A lot of the initial stage was unclear and I needed a lot of reassurance about the visa trumping the Schengen 90 days. (The Local helped on that one),” she wrote. 

“[The] lack of ready communication was very stressful. It could be slicker, however staff at Manchester TLS were excellent.”

Jacqueline Maudslay, meanwhile, described the process as “complicated”, saying: “The waiting times for the appointment with the handling agent (TLS in the UK) are long and difficult to book online. We applied for a long-stay visa and were given a short-stay visa, with no reasoning and no option of talking to anyone.  

“We had met every criteria for the long-stay visa. There needs to be a contact link with the French Consular website directly for discussing visa applications.”

Handling agent TLS’s website – the first port of call for applicants from the UK – was a target for criticism.

“The TLS system is probably the most user unfriendly system I have ever used,” wrote Susan Kirby. “It throws up errors for no legitimate reason and even changes data you have keyed in. Dates are in American format so you have to be very careful and it can be very difficult to edit.”

Bea Addison, who applied for a visa in September 2021 with a view to retiring in France, agreed that it was complicated and believes the French system is chaotic and badly organised compared to other countries. “Even staff in the French Embassy in London were not knowledgeable of the process and documentation,” she wrote.

“The renewal in France was applied for in July 2022 … we have received an attestation that we will be granted renewal visas, which expired in October 2022, but we have not yet received a date to attend the préfecture due to a backlog.

Second-home owners

Many of our survey respondents were not moving to France, but were instead second-home owners who did not want to be constrained by the 90-day rule.

They have the option of remaining residents of the UK and applying for a short-stay French visitor visa – which must be renewed every year.

Second-home owner Peter Green told us: “Our appointment with TLS was delayed by two and a half hours and the whole experience was chaotic.

“We now have to go through exactly the same process again to get a visa for 2023. With second-home owners there should be a fast track that just involves proving financial viability, nothing else has changed. The system needs to be fully computerised.”

Second-home owner Alan Cranston told us his application met with no problems, but came with “unwanted cost and effort”. 

“Our six-month visa was for our first stint at our house in France in the spring, and that then overlapped our second visit in the autumn which was under Schengen. How that is handled seems to be a muddle (we did not leave the country for a day at the end of the six months, as some advise),” he said. 

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