Any recommendations for retirement consultant?

Hello all,

I’m relatively new to the forum but I have enjoyed reading through all of the great pension advice on the forum so though I’d try my hand with a question. I wanted to see if anyone has used a retirement advisor in France and if so if they’d pass along a recommendation to me. I’m not talking about someone for investment help (though that might be useful too), but instead an advisor who can walk me through future pension entitlements in the UK, US and France depending on various scenarios of working/ not working between now and UK age of retirement of 67. I will include some further details about our situation below in case anyone has first hand experience of any of these questions too, but primarily we are looking for a recommendation for a retirement advisor.

My husband and I have been resident in France since late 2020. We moved into our second home in France in a hurry just before Brexit so we did not do any financial planning before we moved over and as a result left the bulk of our financial assets in the UK. We do have one personal pension pot (with PensionBee) which may be moveable to France (if that is still an option) but the bulk of our retirement income will come from rental revenue from UK properties, state pension and a few defined benefits pensions; none of these assets are sensible to liquidate or move.

My husband is starting to think about stopping work, but ideally we would like a clearer idea of what stopping would mean in terms of French pension incomes/ heathcare entitlement and S1s. We know that he will be eventually entitled to a full UK pension, but would like to find out more about entitlements to French and US pensions.

French Pension: I can see some online references which say that people who moved to France before Brexit might have the right (depending on the caisse) to decline a French pension in order to qualify for an S1, though it seems like experiences I read on this forum run contrary to that. If declining a pension is not possible then we would like to know how to calculate what my husband’s possible French pension might be from his few years of consulting via a microenterprise here in France. We do have some estimates from Info retraite, but we are interested in a scenario of stopping work but not declaring retirement until 67 which their estimates do not seem to cover.

Partial US Pension: We would like to know whether my husband would be entitled to a partial US pension from working 3 years in the US in the past. I know that that is short of the 10 years required by the US on a standalone basis, but it seems like maybe there is a possibility that he could unlock a pension entitlement due to the Social Security Totalization agreement between the US and UK, even though the amount would be severely pro-rated by the fact that he only worked there for 3 years. The examples that I see online talk about pro-rating both pensions so maybe the fact that he has a full UK pension would cancel this possibility out anyway.

Anyhow, that is already way longer than I intended this post to be so I’ll stop there with the questions. If anyone has any past experience of these questions or a recommendation for someone who can advise on these sorts of things I would greatly appreciate it.

If you’re looking for someone who will come and see you, it would be useful to know where you live.

On Zoom is better, because then you are not dependent on someone local, but can be a well recommended adviser from anywhere in France.

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The difficulty is that no/few people are qualified as advisors in all three countries. You may have to research options in each country and pull it together yourself.

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Can you help here @GeorgeSymes_IFA ?

Thanks for the responses. I agree that Zoom would be best because JaneJones is correct that it is difficult to find anyone with knowledge of all three regimes and I had no real idea to find one in my particular area.

I may need to go with separate advisors as suggested, or there is a person in Paris who seems to feel he could help, but he also seems to be a one man band and perhaps over keen on drumming up business, or perhaps I am just an untrusting soul.

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@JaneJones is absolutely right about few, if any people being competent to advise on all the various technical issues you’ve highlighted. Having previously worked in a global network that does exactly this type of thing, you would be very unlikely to find one person/team who could possibly know the issues in any depth, without having to sub contract to relevant specialists in the various countries concerned. Advice like the type you’re seeking is also, unfortunately ,very expensive..

Thanks for the reply. This is what I secretly feared. I appreciate you taking the time to reply.

Best,

Stephanie

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If you are going to have to go it on your own, and for sure George1 is right, some random thoughts

Advice will depend on what are your aims. Pre- and post-retirement. Noting that you haven’t said how many years you have till retirement and when would take UK state and DB pensions, and DC (personal) pension(s).

Personally I’d tackle the US pension and what could be done with it, and any interaction with the UK state pension, first. If there is a pro rata on the two together but the US pension is higher per year, then probably you should look at this. Or what else could you do with the US pension ? There may be something else completely different you could do with it depending on your situation. Eg does the US have arrangements that port to any other country you might be connected with ? including France?

Your eligibility for an S1 from the UK DWP at retirement on UK state pension, is, I believe, determined by the last country you worked in. As that then becomes your responsible / competent country. If the last country you worked in was the UK then’s that’s your competent country ie so far as I understand it, so S1.

For the gap till retirement, for instance I commuted to perform work in the UK on a regular work pattern whilst resident in France. So I was technically a frontier worker working in the UK. For that, UK HMRC was able to issue me an S1 every year that I did that ie a working S1. My sort of work required me to bill clients via a UK Ltd company of which I was an employee. So the company got paid my full invoices and obviously paid my expenses. My expenses were mostly paid to me by the company tax free. Although home to work costs had to be thought about carefully in this regard.. I was taxed, and only in France, on whatever salary or dividends (historically better position on National Insurance after a minimum salary is paid) I took. So revenue payout could be timed. Or at that time and so far (but watch the new Chancellor carefully), money could be paid from the company into a pension pot taxfree (better than by the individual as also taxfree, but with the money having incurred Employer N.I. as well as Employee N.I.) up to £40-60,000 per UK tax year, depending on the rules of each year. If I’d had enough revenue to be able to do that, I’d have had to observe the rules around French pension contribution limits too but defo still worth it.

If your OH did something similar, this could give flexibility of taking or not taking revenue earned till wanted, and carefully positioning the date so it falls into the same or different tax years of France vs UK. Just beware that any work performed in France must have social contributions made on it even if for a UK company. These are significant, and so is the admin sorting it out.. So if the work being billed via UK co was performed outside France, it would be simpler.

I gather it can be extremely beneficial to delay taking a French pension even a little time, and there is a little (though much less p.a ) advantage in doing the same with UK state pension.

Beware UK Chancellor may in due course reduce pension advantages further, particularly on the withdrawal/ lump sum side, after her last attack.

Rental revenue from UK properties is still declared and taxed first on the UK tax declaration you will still have to make, and also declared in the right box on the annual French tax declaration where it won’t be directly taxed by France bur will count in your global income declared to France so might shift you to a higher French tax threshold overall. So you will need to keep up with the UK Chancellor’s ideas :slight_smile: and retain a UK strategy ongoing anyway.

As and when I had a change in properties, if I was a UK landlord I’d look at putting any new property into a company (as just moving held property into a company will trigger CGT and have other costs). I gather some landlords in the UK have been doing that with changes in the past few years and more quite likely to come.

Thanks so much for the response.

I am going to take your advice and start with the US. I’ve made an enquiry with the SSA in Paris so we’ll see what comes of that. From what I have read online I do believe that my husband will be entited to some small amount of US pension, even though he did not work the requiste 10 years there, because of the way the tax treaty is written, but I guess we’ll see what materializes. We are not really counting on it but it’s silly not to ask.

Your comment on S1 eligibility is not good news, but is what I have seen elsewhere on this forum so not unexpected. We’ll see what happens but a last contract as a frontalier commuting to the UK could be a possibility worth thinking about.

Mostly I just don’t want to do anything really stupid that either decreases our chances of getting an S1 or barring the possibility of the S1 decreases the amount of his French pension. I’ll check back in if we come up with a good option.

Best,

Stephanie