UK government pensions and social charges: has French law changed?

Reader question: I am a retired UK police officer receiving a ‘government’ pension. I have been a tax resident in France since 2021. Up until now I have not been subject to social charges, with a credit being applied equivalent to the tax and social charges that would have been levied. However, for the 2025 tax year my accountant insists that my UK government pension will be subject to social charges and I should declare them accordingly.

His reasoning is that something was changed by the MPs in December, which “closed a loophole” for some non-EU citizens who are residents in France. He says it means I fall within the PUMA scheme for healthcare and being thus affiliated to French compulsory healthcare, social charges should be applied to my police pension until such a time as I have an S1 form.

Throughout 2025, readers increasingly reported that some local French tax offices were charging social charges on their UK government pensions, despite this not usually having been the case in previous years.

This was often the case for people receiving a government pension who were not (or not yet) receiving a state pension from their country of origin. 

After ‘MAP’ procedures were launched by some of those concerned – in this case involving dialogue between UK and French tax officials – the French authorities confirmed that this treatment was incorrect.

We are not aware of any change voted in December last year that would have overturned this.

The accountant may be referring to the fact that the social security finance law, voted in December, included at article 53 rules implementing a new ‘financial participation’ (fee) for certain people who live in France off foreign incomes that are exempt from the social charges due to tax treaties. 

This can include people who receive UK ‘government’ pensions (‘government’, referring to certain public sector pensions, such as those paid to former police officers or state school teachers).

The new fee, yet to be put into action (a decree is awaited), confirms that people who have a right to French health cover under the PUMA (healthcare by residency) principle, should pay a fee towards this if, due to treaty rules, they are not already paying the French social charges. 

This is expected to be a specific new healthcare fee, not a new social charge (prélèvement social) that will be levied on certain categories of income. The amount of the fee has not yet been clarified.

Note that a minority of such people already pay a fee called cotisation subsidiaire maladie, but only where they have substantial investment incomes.

This new rule also confirms the fact that France today expects that those who are stable residents in France should join the national healthcare system (eg. as opposed to staying indefinitely on comprehensive private policies), however this was already the case based on previous laws.

Treatment in France of some foreign pension income

People who are affiliated to the French healthcare system – unless their care is paid for by another country under the UK/EU S1 form scheme – are considered à la charge de (a responsibility of) the French system.

This means they do not qualify for a specific exemption from French social charges that relates to foreign pension income received by people whose healthcare costs are not covered by the French system. This can include, for example, UK state and private pensions of British state pensioners, who are entitled to UK S1 forms.

The notice (notes) to the 2047 foreign income tax form, on page 3, under the heading Revenus de source étrangère imposables aux contributions sociales, confirms the rule that foreign pension income (referred to as revenus de remplacement because it replaces work income) is not subject to CSG and CRDS social charges if the recipient is not a burden on the French healthcare system. 

This also applies, where relevant, to the CASA social charge on higher pensions.

We note also that anyone who lives in France and is affiliated to social security but does not benefit from an S1 would be seen as a burden on the French system, whether or not they pay a fee for this.

Double tax treaty rule

However, regardless of this rule, UK government pension income of retired Britons in France is free of French social charges due to a different rule in the UK-France double tax treaty.

The treaty treats the social charges in the same way as income tax, grouping them together as forms of ‘French tax’ for purposes of the treaty rules, in article 2.

Article 19 (government pensions) says UK government pensions of Britons in France are taxable only in the UK and article 21 (elimination of double taxation) sets out the rule whereby for this kind of income a French tax credit is awarded, annulling the amount of theoretical ‘French tax’ (there is an exception where the recipient of a UK government pension lives in France and is French, and only French).

The DGFiP (central tax authorities) confirmed to The Connexion last year that the charges form an “indivisible” package with income tax when applied to UK government service pensions, adding that “it is not possible to levy the social charges on these revenues received by British nationals fiscally resident in France”.

There is nothing in article 53 of the social security finance law that would change this fact or overturn a double tax treaty rule. 

Furthermore, even if there was, treaty rules have higher legal authority than laws passed by the national parliament.

We therefore still see no reason for French government pension income to be subject to the French social charges, whether the recipient has an S1 or not.

You can read more about the French tax treatment of UK government pensions in our guide French Income Tax 2026.