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Discussion Starter · #1 ·
Hi,

I just joined this forum today so I could be asking questions already covered....apologies in advance if that's the case....

Im irish and my husband is UK and we moved to France 1 month ago. My husband is working with an international aid org who are tax exempt. I'm not working right now because I stay home with our 1 year old. As soon as I secure a good crèche/child minder I will look for work. Right now I am only paying income tax and social insurance contributions in Ireland on investment income that is generated there.

My questions are:
1. Is there a difference between PUMA and the regular health insurance granted to French nationals?
2. Can my Irish tax & social insurance contributions be transferred to France and used to obtain the carte vitale?
3. In Ireland, people whose only income is from investments are considered self-employed. Is it the same in France? If yes, does this mean I don't have to wait for 3 months residency before I can apply for the carte vitale (i.e because I am already considered employed)?
4. Will my husband and child also be able to get the carte vitale based on the taxes I am paying? Even f they are paid in Ireland it's still the EU and I read that I should only pay tax in one EU state I.e. I cannot be taxed in Ireland and again in France.

I'd like to say a special thanks to Bev for posting the English guide to French social security. It clarified a couple of things for me but as u can see I still have many questions! Hope somebody can help and my case is not too complicated!

Thanks
GG
 

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Have moved you to a thread of your own in order to generate a few more responses.

1. Is there a difference between PUMA and the regular health insurance granted to French nationals?
No. PUMA is the national health insurance program, though the emphasis when speaking of PUMA is more on how eligibility for coverage is determined.
2. Can my Irish tax & social insurance contributions be transferred to France and used to obtain the carte vitale?
No. Not unless you can get an S-1 form from your national social insurance agency - which is normally not the case unless you are drawing a government pension.
3. In Ireland, people whose only income is from investments are considered self-employed. Is it the same in France? If yes, does this mean I don't have to wait for 3 months residency before I can apply for the carte vitale (i.e because I am already considered employed)?
Again, no. But your husband's job should include family coverage in whatever health care program he is currently covered by. (Some NGOs are part of a special "cotisation" system that, while "private" works much like the various national systems.) He should inquire about your coverage with his employer.
4. Will my husband and child also be able to get the carte vitale based on the taxes I am paying? Even f they are paid in Ireland it's still the EU and I read that I should only pay tax in one EU state I.e. I cannot be taxed in Ireland and again in France.
No, not based on what you're paying. But the whole deal with PUMA is that health cover is now based on residence in France. However, given that your husband is employed by an international organization that could be considered an NGO, you should look to that cover first for the family. The PUMA residential based cover is normally only available to those with no other mandatory health cover available (which usually refers to coverage through employment).

You may also want to take a look at whatever tax treaty there is between France and Ireland. The terms vary on how investment income is taxed, but you will need to file a declaration at the end of the year, including both your income from investments and your husband's salary from his job. You won't pay any double taxation on the income - there are places on the form to indicate the tax-free or exempted status of the income. But you may pay some "social insurance" tax on the investment income (again, it depends on the tax treaty). Although many people refer to this tax as "cotisations" it does not entitle you or your family to French health cover.

Don't forget, too, that even if you wind up with the French health cover, the system here does not pay for 100% of all medical costs. You will need a mutuelle as a top-up plan. (Though there may be something available through your husband's employment if he has the NGO plan.)
Cheers,
Bev
 

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Where is your husband working? If he is based in France his employer has a responsibility to enter him into the French health system. If he is based overseas but physically does the work that opens up another scenario. Once his health cover is sorted out his dependents will also be covered.
 

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Discussion Starter · #4 ·
Thanks for the replies.

We live on the Franco Swiss border (on the French side) but he works in Switzerland. He is on a type of temporary consultant contract with the NGO so he is not enrolled in any health care program with them. We have spent the last month enquiring about private health insurance options but we found that none of the private options are better than PUMA in terms of cost versus coverage. So we would prefer to be in the French national system if possible.

I've heard about the S1 but I dont know if I'm eligible for it. Does anybody (non pensioners) have experience obtaining this from their home country?

My understanding about the French system is that if you work in France you are enrolled immediately and if you are resident in France but inactive (like me) then you have to prove you have been legally resident for minimum 3 months. In case of enrollment based on residency, are there other conditions that have to be met e.g. minimum cotisations paid? If so what is the % of income that needs to be contributed to be enrolled in PUMA?

There is a taxation treaty between Ireland and France which states that you pay income tax in only one of those states. Logically I would want to be covered by social security in the state where I am resident for the next few years. So the tax and social insurance contributions I'm paying in Ireland should be transferable to France....which brings me back to my S1 question!

I did go to my local CAPM office but they didn't have anybody who spoke English and with my limited French they send me on a wild goose chase and I left more confused than when I had entered :(
 

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My understanding about the French system is that if you work in France you are enrolled immediately and if you are resident in France but inactive (like me) then you have to prove you have been legally resident for minimum 3 months. In case of enrollment based on residency, are there other conditions that have to be met e.g. minimum cotisations paid? If so what is the % of income that needs to be contributed to be enrolled in PUMA?(
If you work in France you pay contributions via your employment (employer contributions and employee contributions, or self employed contributions if you're say a consulltant). As Brit said, the important link in the chain is being registered with URSSAF as an employee so that these contributions can be collected. Living and working in France and not paying contributions is a no-no, unless you are covered by the social security system of another EU state due to being a posted worker/cross border worker/whatever; these circumstances are clearly defined under EU regulations.

The requirements for PUMA are "stable and legal residence" which basically means having somewhere to live and enough income to support yourself. Fiscal matters in France are usually done on a household basis, so it's your household income that's assessed, and if your OH is working full time and paying his dues then it's unlikely that you would pay any extra contributions, you would be covered by his. If for some reason his contributions were below the threshold during the calendar year, you would be reassessed. For inactifs who pay no cotisations, I believe you contribute 8% of household income above a certain limit (somewhere around 10k°

If you're not in receipt of a UK pension then except in special circumstances the UK will not give you an S1.

You seem very worried about healthcare but in fact the system is designed to ensure that everyone who lives in France and follows EU/French rules is fully covered, and contributes in line with their ability to pay.
 

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Even if your husband is actually working in Switzerland, the employer should be doing something about enrolling him in the French health system - it's usually covered under the "frontalier" workers rules and regulations (I think). Not sure how it works in Switzerland, but I know when I worked in Germany, some of our employees lived in France and had to be enrolled in the French cotisations system, for which the employer pays a portion.

You really need to have your husband check with his employer, because if he's enrolled, then the whole family is. You can't cotise (i.e. pay into the system) based on your foreign investments, but whatever cover your husband has through his employer covers the whole family. (The Swiss system is based on private insurance, but I believe the employer is still obligated to pay at least part of it.)

You may wind up having to find a mutuelle to cover the top up stuff - but you'll get a much better deal if you enroll the whole family in the same plan. However, first you have to get the issue of the basic national cover resolved.

If all else fails, you can go talk to someone at the local CPAM and ask them how to arrange this. It would help if you brought information about your husband's employment because in any event, if you wind up registering directly with PUMA, the amount you pay is based on your household income - not your separate incomes.
Cheers,
Bev
 

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Thanks for the replies.

We live on the Franco Swiss border (on the French side) but he works in Switzerland. He is on a type of temporary consultant contract with the NGO so he is not enrolled in any health care program with them. We have spent the last month enquiring about private health insurance options but we found that none of the private options are better than PUMA in terms of cost versus coverage. So we would prefer to be in the French national system if possible.

I've heard about the S1 but I dont know if I'm eligible for it. Does anybody (non pensioners) have experience obtaining this from their home country?

My understanding about the French system is that if you work in France you are enrolled immediately and if you are resident in France but inactive (like me) then you have to prove you have been legally resident for minimum 3 months. In case of enrollment based on residency, are there other conditions that have to be met e.g. minimum cotisations paid? If so what is the % of income that needs to be contributed to be enrolled in PUMA?

There is a taxation treaty between Ireland and France which states that you pay income tax in only one of those states. Logically I would want to be covered by social security in the state where I am resident for the next few years. So the tax and social insurance contributions I'm paying in Ireland should be transferable to France....which brings me back to my S1 question!

I did go to my local CAPM office but they didn't have anybody who spoke English and with my limited French they send me on a wild goose chase and I left more confused than when I had entered :(
Assuming your husband is a cross-border worker, but not an employee of the NGO - is that right? If so (neither of you is working in France), then as residents of France you will both need to register for PUMA via CPAM. If you can't cope with the language issues and CPAM does not have an English speaker, you will need to find someone to assist you.

You need to sort out the Irish end. Perhaps the first question is whether Ireland will issue you with an S1 (which I guess would then cover your entire family). However, you also need to sort out the issue of being self-employed as an investor. That means you need to determine where you are tax resident - and you are most likely tax-resident in France, not Ireland (although I guess Ireland would tax you on any income from real property investments, as opposed to financial, that being the standard arrangement - but that doesn't mean you would be tax resident in Ireland). So, if you are resident and tax-resident outside Ireland, I don't see how you would still be connsidered self-employed in Ireland and therefore you would cease to make social security contributions there (but you need to sort this with the Irish authorities).

Living on investments is not generally considered to be self-employed in France, although you would declare your earnings and they would be taken into account in your household tax assessment.

Forget the transferring of your Irish health cover to France unless you have an S1 - it simply doesn't work that way.

What health cover are you currently relying on?
 

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Assuming your husband is a cross-border worker, but not an employee of the NGO - is that right? If so (neither of you is working in France), then as residents of France you will both need to register for PUMA via CPAM.
I don't see how this lines up with legislation? If hubbie is working, and living in the EU, then he has to follow EU rules for workers, he can't claim to be inactif. He woud need to be registered either as an employee or as self employed. The rules for cross border workers don't leave any wiggle room to opt out of social security payments - either you contribute in the country where you work (if you meet the criteria for cross border commuters), or you contribute in the country where you live (if you don't), and whichever it is then that is your competent state and covers you in both countries.
Cross-border commuters - Your Europe
 

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Just to clarify here - if hubby is working for/with an "international aid organization that is tax exempt" I'm assuming that means an NGO where his salary is not taxed in France. Normally speaking, these types of NGOs have a special social insurance scheme that applies across all sorts of NGOs, from the EU to the UN organizations to the sorts of international aid organizations like the Red Cross and whatever. It's separate from the national social insurance schemes, but it does cover both the employee and his or her immediate family members.

If your husband's employer has no such coverage, or if he's somehow working as a volunteer or something, then you need to go to CPAM with all the relevant information and see what they have to say about PUMA or whatever cover you are eligible for.

But you don't get to choose where you pay either your taxes or your cotisations/social insurances. There are rules in place, and you just need to find out which rules you fall under.
Cheers,
Bev
 

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Discussion Starter · #10 ·
I think I'm slowly piecing all of this together and will soon have clarity (or maybe that's just wishful thinking!). But this whole subject does seem more complex than I hoped. Or maybe it's my situation that's complex because:

1. Im resident in France and inactive but I do pay tax and social insurance in Ireland based on investments I have there
2. My husband is a Frontalier (working in Switzerland but living in France) with tax exempt status

So neither of us are currently paying taxes in France but we would like to contribute to the French system and be enrolled in the country where we physically live. I understand that we cannot be enrolled if we are not contributing and that's why I'm trying to understand how we can achieve this while not ending up paying tax in 2 countries....

So I guess my questions now are:
1. Can I be enrolled in the French system based on my irish contributions i.e. by obtaining the S1 (which a previous poster said is only available to pensioners?!).
Do any non pensioners out there have experience obtaining the S1?

2. OR can I change my tax residency to France instead of Ireland based on the fact that I should pay tax in only one of those countries? What criteria is used to determine where a person is tax resident?

Cheers
 

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How long have you lived in France? Have you completed a French tax return? France will consider you as a French tax payer as soon as you become resident in France and will expect you to declare your worldwide income and bank accounts. Whether you pay tax in France or Ireland will not be your choice. Some income, Government pensions and income from overseas property, for example, would not be paid in France, tax on other pensions and investment income would.
The real problem is your husband's status and I believe that he has to sort that out with his employer. He is employed in Switzerland and although he pays no tax he still needs to be considered as someone who is a potential taxpayer who needs medical cover paid for by the country where he works, where he and his employer contribute to the system. You might have to get expert help to discover if Switzerland is able to issue him with the equivalent of a worker's S1 and whether France, where he is resident, will accept his tax free income. They might insist that that income is taxed in the same way that they tax pension lump sums and Premium Bond wins which are both tax free in the UK. As it stands you are hoping that France will provide you with health cover to you as immigrants despite your income from employment coming from other countries and possibly, at present paying no tax or social charges (not the same as the 8% paid towards PUMA) in France.
 

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You need to go back and read the replies you've had so far. You seem to be basing your questions and concerns on the "old" system - where you had to have some method of contribution to be part of the French health care system. That system changed last year when PUMA came into place. PUMA is a residence based health coverage system.

However, if your husband is working for a tax-exempt charitable or NGO organization, they most likely have some form of health cover that is part of his pay. If they do, it is not part of the national social insurance plan of any country, but is a sort of private arrangement that is portable across borders (at least within Europe).

So neither of us are currently paying taxes in France but we would like to contribute to the French system and be enrolled in the country where we physically live. I understand that we cannot be enrolled if we are not contributing and that's why I'm trying to understand how we can achieve this while not ending up paying tax in 2 countries....
This is the problem - you do not have a choice in where you pay taxes. I would check first of all to see what the situation is in the France-Ireland tax treaty to see just where you are supposed to be paying taxes on those investment. It's likely that you'll be paying to Ireland, but it never hurts to check these things out when you move.

Secondly, there is a line on the French tax declaration forms for indicating that someone in the household (i.e. your husband) is receiving salary from a tax exempt organization. You will not be taxed by France on that income, but it will be taken into account for various administrative things - and you will need the tax assessment form (even if it indicates 0 tax paid).

If you have only been here a month, chances are your husband has not yet received his first pay slip. There should be some listing of the relevant deductions on that pay slip and one of them will probably be for the health care plan that the employer subscribes to. He needs to ask his employer about this and how it works, but you are covered, even if not by the national system. It's a common arrangement for those who work for the various international "civil service" agencies. But if there is this type of employer plan available, you can not enroll in the CPAM system.
Cheers,
Bev
 

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Discussion Starter · #13 ·
Some previous posts have suggested that an S1 form is only issued for pensioners. But I just found an official EU site which says:

"If you work in one EU country and live in another, you are entitled to medical treatment on both sides of the border.

Register in the country where you work and get an S1 form (former E 106 form) from your health insurance authority. This form entitles you and your dependants to receive healthcare in the country where you live.

Your dependants can also enjoy the same rights as you if you work and are insured in most EU countries.

If you work and are insured in Croatia, Denmark, Finland, Iceland, Ireland, Norway, Sweden or the United Kingdom, your dependants can receive treatment in the country where you work only when one of the following conditions is met:
treatment becomes necessary on medical grounds during their stay in that country, taking into account the nature of the treatment and the expected length of the stay
there is an agreement between the countries/authorities concerned
prior authorisation has been granted using form S2 (former E 112 form) issued by the competent health insurance authority in the country where you work.

Caring for sick children
As a cross-border commuter, if you take time off work to care for a sick child, check with your health insurance whether you qualify for benefits. You may not if your child is insured together with your partner in the country where you live."

So it appears the S1 is issued to cross border workers so they can be insured also in the country where they live. It's not some magical document we have to wait for until we reach pensionable age....
 

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Not all countries issue the S1 in the manner you describe. But rather than worry and wait, you should go to the CPAM and explain your situation, bringing documents that show where your husband is working, etc. They will be able to tell you whether or not you are eligible to sign up for the French system and/or if there is some other arrangement due to your husband's frontalier status.
Cheers,
Bev
 

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Let's not forget also that Switzerland is not an EU country. Your husband works in Switzerland but is he employed in Switzerland or is he employed elsewhere and posted to Switzerland?
 

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You're correct. In the circumstances the first thing to do is to apply for a workers S1 from Switzerland. If this is issued you have your solution. If it isn't you'll have to think again.

Potential hiccups are Switzerland's status with the EU and the exact parameters of OH's job but the only way to find out is to apply and hopefully there will be no hiccup.
 

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Although thinking about it, you said earlier that his employment doesn't provide any state healthcare at present, which not usual. Usually when you work in an EU state you are entitled to join its national health service by virtue of employer/employee contributions, and the workers S1 is issued by that state because it is responsible for you. If the state is receiving no employer/employee contributions for him and isn't responsible for him at present, would they issue an S1, hmm, doubtful. Maybe it is all to do with the special rules for aid organisations. But, since the workers S1 would be the normal route, then unless CPAM is au fait with how things work with aid organisations that is the route CPAM will expect you to try first. If it's refused, they will probably want to see that you applied and see the letter of refusal to understand the reasons for refusal, before they can look into other routes.
 

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Exactly, EuroTrash. And there IS a sort of NGO "international civil service" benefits plan - which is not a state plan - which is supposed to be obligatory for employees of certain international organizations (certainly the ones where the salaries are tax exempt).
Cheers,
Bev
 

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The OP's OH is a consultant for an NGO on a contract and therefore possibly (likely?) not an employee at all.
Which is why I think she needs to go talk to the folks at CPAM and see what they have to say. In any event, she'll need to get the list of what documents they will want to see - and it can vary a bit from what's posted on any website, given the somewhat different circumstances.
Cheers,
Bev
 
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