Live / Work UK, Live in France

[Polemicuss]

All,

I have read a lot of threads on the whole UK/France healthcare but havent found one that exactly meets my situation.

I will be offered a position in the UK - (I have US + Hungarian passports) contract will dictate I work 3 days a week in the UK office so as to avoid me claiming France as work place and claiming the huge liability that comes with that. I will have an address in the UK but I will actually be living in Paris (I am in sales covering all of Europe).

So technically I would be a resident under both UK and France law I believe although pay taxes in UK and take advantage of the reciprocal agreement to not pay taxes in France.

1) So in this situation - can I get healthcare in France? Everything I read was about temporary trips to France or retirement not long term living there.

2) I know I cannot use my UK Child Vouchers in France but will I be able to enroll them in the "Catholic partly subsidized" schools in Paris with a UK paycheck?

Does anyone have some good agencies (lawyers accountants, relo, etc) I can talk to about this? Thanks!

[Bevdeforges]

If you're not paying into the French cotisations system, and not presenting an S-1 from the UK to take advantage of the "transition" arrangements, then I think you'll be stuck with travel insurance for France.

As far as the children are concerned, to enroll them in a French school (even partially subsidized), I believe you will need to show that they are covered by your health insurance - which could be a problem.

Technically speaking, it's not only the 183 days a year thing that determines your tax residence, but also where you have your "centers of interest" - which includes where your family is living while you're working. If your family is going to be living in France, there is a strong argument that you are indeed "resident" in France, even if you're working 3 days a week in the UK. (Certainly from the French side.)

In the current austerity climate, I'd make sure my employer was party to any arrangement regarding a split living situation like this, and see if their legal department can help smooth the way.
Cheers,
Bev

[-mia-]

I was going to say the same as Bev. If your children are living and going to school in France (with presumably a spouse?) then your "centre de vie" is in France and the French will expect that you pay taxes there.

[Polemicuss]

Originally Posted by -mia-

I was going to say the same as Bev. If your children are living and going to school in France (with presumably a spouse?) then your "centre de vie" is in France and the French will expect that you pay taxes there.

Yes but there is a reciprocal tax agreement with the UK where France will count taxes paid to the UK against their taxes and since France taxes would be lower becasue of the "household" parts - there should be no tax due to France. But I can still claim myself as a resident. In this situation would they just take into account that I am paying into the UK system and send the bill there so I can get a carte vitale? I gues the key is understanding if I qualify for an S1.. I read this on the French Entree site...

"A worker’s S1 form is available to those who move to France, but who continue to work in another EU member state. It is based on your ongoing national insurance contributions in the UK. Furthermore, it should last for the duration of your time working in the UK and is not restricted to a maximum two and a half years like a normal S1."

[Bevdeforges]

The trick is that of getting the S-1. We've had a few reports of folks having difficulty in this regard - make sure your employer helps you with this (since they're the key beneficiary of your not having to pay French cotisations!).

Once you have the S-1, you can apply for a carte vitale. Just remember that the French system is a reimbursement system - you pay the doctor, lab or care provider and then are reimbursed, usually at about 70% of what you paid. Normally, in France, the employer pays for part of a mutuelle (or top up insurance) - and you might want to negotiate this with your UK employer. Otherwise, a mutuelle will run you about 60 - 120€ a month per adult covered and another 40 - 75€ a month per child covered.
Cheers,
Bev

[-mia-]

Originally Posted by Polemicuss

Yes but there is a reciprocal tax agreement with the UK where France will count taxes paid to the UK against their taxes and since France taxes would be lower becasue of the "household" parts - there should be no tax due to France. But I can still claim myself as a resident. In this situation would they just take into account that I am paying into the UK system and send the bill there so I can get a carte vitale? I gues the key is understanding if I qualify for an S1.. I read this on the French Entree site...

Of course you can't be taxed twice on the same income. I'm actually surprised that you would pay less in tax in France than in the UK.

[Bevdeforges]

Originally Posted by -mia-

Of course you can't be taxed twice on the same income. I'm actually surprised that you would pay less in tax in France than in the UK.

Less income tax, most likely. It's the cotisations that the employers are looking to avoid (since the employer portion works out to something like 40% of gross salary). Also, France gets more of its revenue through VAT than through income taxes.
Cheers,
Bev

[Sarah B]

Originally Posted by Polemicuss

Yes but there is a reciprocal tax agreement with the UK where France will count taxes paid to the UK against their taxes and since France taxes would be lower becasue of the "household" parts - there should be no tax due to France. But I can still claim myself as a resident. In this situation would they just take into account that I am paying into the UK system and send the bill there so I can get a carte vitale? I gues the key is understanding if I qualify for an S1.. I read this on the French Entree site...

"A worker’s S1 form is available to those who move to France, but who continue to work in another EU member state. It is based on your ongoing national insurance contributions in the UK. Furthermore, it should last for the duration of your time working in the UK and is not restricted to a maximum two and a half years like a normal S1."

Regarding the S1, you need to have paid a certain amount of national insurance contributions in the UK before you are eligible. If you find that you are eligible, you will have to fill in various forms and await reception of the paperwork, which can take some time and you normally need to renew your S1 every 2 years to be eligible to keep your Carte Vitale. If your wife is working in France, on a French contract, then she will be eligible for a Carte Vitale and will be able to put the children - as long as they're under 16 - onto her card. Working in the UK, would mean that you wouldn't be eligible to be put onto her card.

As Bev has said, it's not the taxes that your employer doesn't want to pay in France, but the social contributions which are extremely high... to pay for the health care system amongst other things.

Good luck

[Polemicuss]

Thanks all for the responses. Actually it is the liability my company is shying away from - much harder to fire someone in France than the UK. I will be working out of the London office (registered UK company owned by my F500 US company). But I will live in Paris. My wife most likely wont work. Would be great to know if i need to live a certain time in UK to qualify for S1 then seems you bring that to CPAM to register for a carte vitale.

Sounds like a good idea to call the Overseas Healthcare Team in Newcastle. Also to work with a Relo Expat to see if there will be any issues renting apartments, registering kids for school, etc. getting a salary in UK but living in Paris. I know vertain things I cant use like the UK child vouchers but dont know if other benefits will be lost as well. Oh well at least the pound is getting stronger while euro seems to be slipping...

Funny I think I saw Bev's post about mutuelle top-up being around 100 or so euros a person. In the US we just assume everything in Europe is covered because of the high taxes. But you pay high taxes in France, they only cover 60-70% and by reimbursement (my plan in US is I pay afterward) then you stil have to pay like $500 bucks (for a family of 4) to cover the rest. For only about $500 a month in the US I get insurance with no co-pay and 90% reimbursed... Just interesting..

[Bevdeforges]

Originally Posted by Polemicuss

Funny I think I saw Bev's post about mutuelle top-up being around 100 or so euros a person. In the US we just assume everything in Europe is covered because of the high taxes. But you pay high taxes in France, they only cover 60-70% and by reimbursement (my plan in US is I pay afterward) then you stil have to pay like $500 bucks (for a family of 4) to cover the rest. For only about $500 a month in the US I get insurance with no co-pay and 90% reimbursed... Just interesting..

Although I really liked Mike Moore's film "Sicko" (or whatever it was called), it drove me nuts when he was promoting the film and talking about people in France getting health care for "free." That's simply not the case.

Of course, over here, you split the cost of the mutuelle with your employer. (Most employers offer mutuelle coverage - though not all.) The employer pays the larger portion, so most workers don't know how much their mutuelle coverage "really" costs. Because we have our own business here, we pay both sides of our coverage - and it runs about 40% of an employee's gross salary (including retirement, which is the big one).

OTOH, there are none of the shenanigans here with reimbursement that you get in the US. If it's on the sécu listing and it was properly prescribed by a doctor, then you're reimbursed, and your mutuelle pays back their share. No pre-existing conditions exclusions, or other ways for insurers to weasel out of paying. Then again, it's the sécu who sets the pricing.
Cheers,
Bev