Retired UK Civil Servants and the payment of CSG

I am receipt of a Civil Service pension although not yet of state pension age. I am taxed in the UK, as per the arrangements of the Double Tax Agreement (DTA). This year, for the first time I was sent a bill for CSG by my local tax office in Carcassonne, which I have had to pay. On the basis of advice from an English speaking tax expert in France I subsequently appealed on the grounds of the DTA, which defines tax as both income tax and social charges. My appeal was turned down on the basis that the Code General des Impots states that where you benefit form the social system, you are liable for CSG, until state retirement age.

Has anyone else experienced this situation? My impression is that the rules may be being interpreted differently in other parts of France and it would be good to know if anyone else has made a successful appeal as I now plan to take my case to the next level, i.e. to a Tibunal. Right now the only solid argument I have is that they have been inconsistent in their interpretation of the DTA, i.e. they have applied if for income tax, but not social charges.

Any advice gratefully received.

Out of all the blokes who play boules at my gaff there are several under 55 & none of them have worked for years! I don't know anybody around here who is over 50 & "works". Somebody has to pay for it! The ones who pay 50% to the state are obviously youngsters awaiting their turn for early "retirement" :-)

I remember recently watching a news report that said the 'average French Worker' works for the government (via taxes, charges and impositions) for six months before earning anything for themselves. This was compared with other countries such as Britain where it is 'only' (?) 4 months.

Amazing how we now accept this robbery as being normal, isn't it?

Not as far as I know , but my wife is French and we are in CMU because of that fact.We pay quite a lot to URRSAF every 3 months as part of that. Neither of us is at UK state retirement age and we did not arrive here until 2009 but as far as I know anyone here before November 2007 could join the Securite Sociale. After that date all cases are dealt with on an individual basis. I think your tax office is creating a smokescreen and this code is irrelevant. The fact is that UK government pensions are NOT liable for taxation in France( because tax has been paid in the UK, and this rule applies in reverse) and taxes in France include CSG etc. It is clearly stated in the Double Taxation Treaty. Any other income eg Annuities, are liable for CSG, etc.

Hi Ian

As a matter of interest, do you and your wife have the number 70 in the Code Gestion box of your Attestation de Securite Sociale? This signifies that you are take in charge by the French Social security system. You may have got this code if you came to France before 2005, or if one of you has now reahed state retirement age. I came in 2005, and am 58, don't have and it is the lack of this code that my tax office is basing its decision on.

What a minefield!!

This is the treaty in force and a read through states that French taxes include CSG, CRDS etc, and a later section says that if tax is paid on income from government service in the UK then it is not subject to any French tax, hence not subject to CSG, CRDS etc. Both my wife and I are early retirers with teaching pensions and we do not pay CSG etc on our teachers' pensions as they are taxed in UK.

You must take this further. Good luck!

Nicholas Pasco of Blevins Franks wrote this in September this year

"Confusion over the French tax, and more importantly, social charge treatment of UK source rental and Government Service pension income has been rife since the latest double tax treaty between France and England came into force. Different French tax offices have been taking different views on how the treaty should be interpreted. Amendments to French domestic laws in 2012 confused matters further.

The position has now been clarified by the Directorate of tax legislation in France. It confirmed that where a French resident receives either:

• UK Government service pension

• UK rental income

and has declared the income to HM Revenue & Customs (HMRC), these amounts will be free of tax and social charges in France."

The trouble seems to be that the tax offices do not apply the rules that have been agreed and finding them on French government websites is pretty near impossible.

I paid social security contributions whilst employed but these ceased on early retirement. I only pay income tax now as I have paid in the required years of SS for a full state pension when I am 66.

You may also be interested in this extract from the Connexion French Tax Return Guide for 2013.

"THIS note applies to foreign rental income and government pensions. Article 6 of the Double Tax Treaty between France and the UK states that UK rental income is assessable in the UK, likewise Article 19 of the same treaty states that "government" income, ie. pensions, are similarly assessable in the UK. Therefore many tax experts conclude that these sources of income cannot be assessed in France and made liable to social contributions. Article 24 of the treaty which deals with the manner in which France applies double tax

relief permits the French to take this income into account in order to boost French tax due on all other legitimately assessable income. However financial adviser Dr Michael Annett of Pelican Consulting said "taking into account" this income does not confer rights of being able to assess it to the social contributions. He said there have also been cases where the appropriate tax credit for French tax has been withheld in

some cases on the grounds that no foreign tax has been paid on these sources of income (due to it being below UK tax thresholds). "This is incorrect according to article 24 of the DTT and the manner in which the tax credit calculation is applied. Also be aware of NOTA in Section III, A.2 on page 2 of the notes to the 2047," he said. There are on-going court cases challenging French tax authorities' application of social charges in this context. Decisions are expected this year. Connexion has also been informed of several cases where readers received a bill for the contributions last year, paid it but then queried it with their local tax office, citing the double tax treaty (convention Franco-Britannique) - and had the money refunded. If you are charged the

social contributions on these sources of income or refused the tax credit for French tax you may wish to seek professional advice.


A senior tax official agreed that in most cases social contributions should not be payable however he added that on going to press a grey area remained where no UK tax was paid. He said that if you have UK rental income or government pensions you may: Declare it as stated in this guide, then: In 2042, page 2, section E – add a note such as this: revenus de eXXXX de locations en provenence de la Grande-Bretagne/ de pension de retraite de la fonction publique britannique [€XXXX of UK rents/UK government pension - include both or either as appropriate] déclarés 2047, section VI et 2042 8TK, Je pense que ceux-ci ne sont pas assujettis aux impôts français, y compris les prélèvements sociaux – Convention Franco-Britannique, articles 2, 24 et 6 [write in the case of rents] or 2, 24 et 19 [in the case of pensions]."

There is clearly different treatment in different areas. My wife and I are both in receipt of Civil Service pensions and have never been charged social contributions in the 4 years we have been here (Dept 26). I have completed my tax returns in line with the above advice and have never had a problem. But ..................

Thank you, Dick.

I think it is because Civil Servants, are only liable to be taxed on their pensions in the country where they were employed. Tax on other income is paid in the country where they are tax resident - I pay tax and CSG to France on income from investments etc.

UK Government pensioners are taxed in the UK. That's teachers, nurses, policemen ex service personnel and many others. They pay more to the UK than they would to France.

And in UK it is called National Insurance. You know, the stamp that all people pay if they have an income. Once retired you no longer pay - same in France.

Just out of interest, why (apparently) are Government Service pensions singled out here? Is this another of the protections provided for being a Civil Servant - e.g. as with protected jobs? Or is this an across the board consideration for ALL UK Pension recipients?

Actually the CSG was introduced already for tax year 1991.
French Wikipedia article on CSG

I am being taxed for this CSG on my global income; that includes my UK state pension. The CSG was introduced in 2012 as a means to screw yet more money out of us, who are struggling as it is to maintain a reasonable life-style and NOT be a burden on the French state. Thank you Mr Hollande!

Hi Peter

Thanks for this very helpful reply.


I am retired and have been hit by a massive increase in my tax payments. I also appealed, and got a slight reduction due to the fact they charged me 7.5% when it should be 6.6%. You mention you will pay this CSG until you retire; not so as you will find, as I am being charged.

Thanks for the explanation of CSG Peter. I do wish people wouldn't talk in shorthand & assume us lesser mortals understand what they are on about!!!

Hi Janet,

Government service pensions are exempt from social charges as you rightly state.

See the following:

There is huge variation in the manner the rules are being interpreted by local offices, but our experience is that most people win in the end.

Before you go to the tribunal try the Médiateur des ministères économiques et financiers