Are there any self employed people who have claimed their french pension? I want to know if the years I worked in the UK are counted in. The english pensions say its not.Anyone with any experience of this?
suzy.
A person may be dual resident (Article 1) but taxation of that person is covered by Article 4 sub para 2.
According to our Uk accountant he is registered as a dual resident. In fact you could be technically resident in 3 countries depending on the amount of days spent in each country of course .France is his main residence but he spends enough time in the UK per year to be classed as a Uk resident
Hi Claire,
I think you will find that dual residency does not exist. Depending on various factors but mainly on how many days in the fiscal year you spend in either country. If it's over 183 days then that is where you are fiscally resident.
Have a look at the recently amended double taxation convention.
That's really bizarre because I work in France, I've been employed and I'm now self employed and had no problem setting up voluntary contributions, in fact i had to prove I was WORKING in France and paying my charges sociales here to be eligeable to pay voluntary class 2 in the UK !!! Having said that there's no point your husband paying them if he's already got his 30 years in for a full state pension. as for the difference in payments in the Uk and France...!
They have told my husband that now he works in france he can't make contributions in the Uk. Wierd as he still works in the Uk , the main part of our buisness is there but they have stopped his self employment contributions even tho' we have been very clear that he is a dual resident and is still running a buisness there. The amount we end up paying here doesn't make it very interesting to pay volantary contributions as well, the self employment rate in the Uk is quite low.
Luckily he has made 35 years worth so whould be covered for the pension as Uk require 30 yeras of contibutions. Who knows what will happen when we get to actualy pick up the pension Via France.
Thanks Claire, that’s very informative - it really is a bit of a headache and I think I’ll stick to paying voluntary class 2 contributions so at least i’ll have one full pension plus whatever I get here too. Although I could find myself hit by the exchange rate as I don’t ever intend going back to the UK (the state pension is the only “string” left tying me to blighty!)
We were told by AVA, the reitrement people( before it was made into the conglomeration that is RSI) when we started contributing here that Uk contributions would count and that we would have to provide paper work from the Uk to show how much my husband had paid. He was self employed in he Uk and now is in France. Being part of the Eu should make things line up but that's an opion not a fact.
I looked up on the net which forms to ask for last year( what you are asking for is a statement of National Insurance) as I want to have them in hand ahead of time. It has taken just over 15 months to get them sorted out as to start they had him working from 1948 remarkable for someone who was born in 1956!! But that's another story. I am keeping it safley tucked away against the day we begin to think out his retirement.
Having googled a bit I have found this as an answer on another forum
"British people who work in France can have any pension contributions paid in the UK counted towards a French pension.
It is calculated differently in the two countries however.
In the UK you have 52 weekly credits in a year.
In France there are 4 'trimestres' ..quarters.
They don't quite add up in the same way, and I found that the French pension authorities didn't give me the full credits I had earned, calculated the British way.
How it works:
To be eligible for a pension you need at least 160 'trimestres', which can have been paid here or in the UK.
They then take a 'salaire de base' which is an average salary over a certain period.
This is multiplied by the number of trimestres worked in France/160
so it could be say 40/160 for someone who has worked here for 10 years before retiring.
It is further multiplied by your 'taux'...is normally 50% if you have worked the required number of years, but this can be reduced as Pornhorn explained if there are some trimestes missing and you go before 65.
Soin the case of the person with 10 years worked in France the Pension would be
'Salaire de base' X 40/160 * 50%
That is 12,5 % of the salaire de base.
This can be taken as soon as you reach 60 if you have the necessary contributions, including those paid previously in the UK
The other 120 'trimesters' would be paid by the UK on the basis if the OAP in the UK, not the basis of the French 'salaire de base', and not until state retirement age in the UK. Presumably in the example I give this would be 3/4 of the OAP for somebody who has the full 30 years required NI contributios, but I can't speak for the UK bit as I am not at that point yet."
Uk Governerment Site Link.
http://www.hmrc.gov.uk/cnr/osc.htm#5
Hope that gives you a start.
This might be a good link but it boggled my brain!!
http://www.ill.eu/?id=2517I'm not sure but I'm self employed here in France and have been employed too so I've contributed to the CPAM and RSI schemes. I've still got 20 odd years before retirement but have 16 or 17 years paid in the UK. I pay voluntary class 2 contributions in the UK to make sure I do get some sort of pension, all be it small :-( and I wouldn't be surprised if the french authorities find a way of not paying me a pension as I won't have paid up the required number of years!
Good luck!