Carte Vitale for UK tax payer?

I think Suzanne answered this,

(URSSAF are the body who collect healthcare contributions)

That’s the bit I find confusing. Is it the company in the U.K. or the individual in France who pays? If it is possible for people to set up UK companies while remaining and working in France why isn’t everybody doing it?

Suzanne - I assuming (?!) that was because the work was physically carried out in France.

Hi, Yes.

Yes, it did. The cotisations are billed to the company. I was registered with URSSAF as the company’s representative in France, and so I paid them myself.

Yes, Anna’s correct. The Ltd company is a separate entity to me, therefore it is responsible for its taxes in the UK, and I, as an individual employed by that company/entity, am responsible for my own personal taxes, which I pay in France.

Both. The company generates a payslip which shows the “employee contributions” that have been deducted from gross salary. On top of that, the company pays the “employer contributions” which are paid separately. I believe it’s much the same in the UK (except in the UK the company also deals with income tax, PAYE, which at the moment isn’t done in France).

A UK company has to pay just the same amount of cotisations for an employee in France as a French company would, and it’s a fairly hefty sum, so what advantage is there? If you already have an established company in the UK then there probably are advantages and it is obviously entirely justifiable, but for a new venture set up by a French resident it is dodgy. Especially since there is the little matter of tax evasion, because if the French fisc believe that you have deliberately set up your business in a particular way purely, or principally, in order to avoid paying taxes, they can penalise you. If you’re charged with setting up a ‘fictitious’ company abroad, you have to be able to demonstrate that your head office genuinely exists and operates and there was a sound business reason for setting up in the UK. It’s not up to them to prove your intention, it’s up to you to justify them so in effect it’s a case of guilty until proven innocent. So if your 'registered office" in the UK is nothing but a PO box or an empty room, you could be in trouble:

“Ces peines sont portĂ©es Ă  2 000 000 € d’amende et 7 ans d’emprisonnement lorsque les faits ont Ă©tĂ© commis en bande organisĂ©e ou grĂące Ă  :


une domiciliation ou un acte fictif ou artificiel Ă  l’étranger.”

French entrepreneurs do it too because the UK has a name for low business taxes, but you need to know the risks and be very canny.

Hi,

I was also confused about it in the beginning, but I had both a French-based accountant (who set it up here and dealt with URSSAF) and a UK accountant who handled the UK side. Both assured me it is not an unusual arrangement.

But we have a dual system still where we only pay in 1 country?

you can live anywhere and have a ltd company in UK

Maybe but you normally can’t be resident in France and carrying out work for that company (in France) without the company contributing to your healthcare etc here. If it was as easy as having your Ltd company set up and the freedom to work throughout Europe with no limits the U.K. reg white van men who seem to be fairly common around here would have an even bigger smile on their faces. My daughter works for a large, London based, firm that has offices two French cities. Each office has a small local staff while others are seconded for just under six months to cut down on paperwork and costs.

I think my original question asked if it were possible to access the healthcare system in France whilst paying tax in UK. From my knowledge you cannot access the healthcare system here without contributing cotisations that goes without saying. Once you leave the UK you are not entitled to UK healthcare unless you have an S1.

Well, as mentioned I think - if HMRC issues a workers S1 so that you continue paying NICs in the UK and the UK covers your healthcare in France, you would be accessing the French healthcare system without contributing cotisations.

TBH I don’t really understand your original question. Paying tax and accessing healthcare aren’t directly related in the sense of one being a consequence of the other, although they’re related in the sense that they’re both decided as a consequence of where you live and work. There are situations where you would pay income tax and NICs in the UK and access healthcare in France, eg if your family home is in France but you commute back to the UK to work. There are situations where you would pay income tax in France but NICs in the UK and access healthcare in France, eg if you normally work in the UK but are on temporary secondment to France.

This thread seems to be getting a bit circular


David - maybe you need to clarify that statement
because it’s incorrect.

In fact you can very easily work for a UK Limited company and be resident in France without that company having any obligation for your French healthcare costs. It all comes down to where the work is physically carried out - i.e. the country where the work is carried out has first shout on the taxation of any revenue generated from that work. If the work is performed in France then yes - you would technically be working for an overseas branch of a UK company - with all the associated implications.

Think about the thousands of airline employees who work for UK Limited companies but live outside the UK. Their income is initially taxed by the UK and also declared in their country of residence for any further consideration. Same goes for those with UK consultancy companies who live in France but perform their work in the UK. The list goes on - it’s not quite as clear cut as you imply.

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I think you’re still confusing taxation and healthcare. You don’t necessarily pay your social security contributions and your income tax in the same country. As you say you pay your income tax in the country where you spend your working time, and that country/company is responsible for your healthcare in the country where you live - so if you live in France, either the UK (S1 + NICs) or your employer (no S1 and no NICs) has to cover your healthcare in France.

Anna - I’m not confusing taxation and healthcare at all. I’m just relaying how it is from personal experience. Your comments have expanded on that in greater detail which may be helpful.

Sorry Simon, no on re-reading it I think it was me that was confused.

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Thanks Anna.

And when the work is in the ether (for uk based company) does it literally come down to which country your sitting in and on which pc??

Yes - absolutely.