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PENSIONS

Is my US pension taxed in France?

Deciphering whether or not you will owe French tax on your US-based pension can be confusing. To give you an answer, The Local spoke with experts and consulted the US-France tax treaty to give an overview of how you might be affected.

Published: 13 June 2024 13:43 CEST
Is my US pension taxed in France?
An older woman reads on the beach of Deauville, north western France, during the 44th edition of the Deauville American Cinema Festival, in 2018. (Photo by LOIC VENANCE / AFP)

When it comes to taxation on foreign pensions, it all depends on the tax treaty between France and the country that is paying your pension, which is why the situation is significantly different depending on where that pension is paid.

Luckily for American retirees living in France, they benefit from a generous US-France tax treaty to avoid double taxation on all pension income, including private pensions. 

To better explain the situation, The Local spoke with tax expert, Jonathan Hadida from HadTax.

“The reason we call France the bees’ knees for American retirees is because US-sourced pension income is only taxed in America. That means when you take money out of your 401(K) or IRA, those are taxable at your tax bracket in the United States. 

“You have to report it on the US-side and pay US taxes at your marginal rate” Hadida explained.

“On the French side, US-sourced pension income is reportable in France for rate-purposes but benefits from a deemed credit.

“This means you put it on your French tax form, and you calculate the tax and you get a deemed credit equal to that. Ultimately, you wind up paying no French taxes on your US-sourced pension thanks to Article 18 of the US-France tax treaty”.

READ MORE: Ask the expert: What Americans in France need to know about 401(k) and other pensions

You should also consider if you have a pension from another country besides the US, as different rules may apply based on that country’s bilateral tax treaty with France. Here is the situation for British, Canadian, and Australian pensions, and here is an overview of the system.

How do I report US-sourced pension income to French authorities?

Although you won’t end up paying French taxes on your US pension, you do need to tell the French taxman about it if you are a tax resident here.

The annual French income tax declaration requires you to declare all global income, including pensions.

Keep in mind that even though you are not subject to French taxes on your US pension, it does count towards your household income which can push you into a higher tax bracket, and this could affect your ability to qualify for certain means-tested grants and government aid in France.

International Financial Advisor, Bryan Dunhill with Dunhill Financial explained: “You fill it in within box 1AL or 1BL on form 20-42 on the French tax return, then you claim it in on the 8TK of the 20-47 to say it is US-based pension income, and then you will get a tax credit from the French.

“It goes in and it goes out on the French side. Being a US retiree in France is fantastic”, Dunhill said.

For both 401(K)s and IRAs, Americans in France should still keep in mind that early withdrawal (prior to the age of 59 and a half) can still lead to a 10 percent early distribution penalty (in the US). There are certain exemptions, such as first time homebuyers and higher education, but you should meet with a tax adviser to determine if you qualify.

READ MORE: EXPLAINED: The rules on tax residency in France

What about social charges?

In addition to taxes (impôts), France also requires people to pay social charges (prélèvements sociaux) on income. However, only specific types of income can be considered for social charges, such as the CSM charge (PUMa) for healthcare. 

The general rule is that pensioners and their spouses do not have to pay the CSM charge, but France specifically exempts people who have a pension from France, the EU, the EEA and the UK (people with S1 forms).

There is some debate over whether common types of American private pensions such as a 401(K) or IRA are treated as a pension (and therefore exempt from CSM) or as investment income (which can attract CSM charges). 

Hadida told The Local: “Under the principle of equality amongst taxpayers, URSAAF has treated most US pensions/IRA distributions/401(k) distributions akin to a French/Swiss/European pension and have therefore exempted Americans with pension income.”

“I have called URSSAF, and I was told by the representative that they should be paying for PUMa. But in practice, I have not seen many American pensioners charged for it.

READ MORE: Cotisations: Why you might get an unexpected French health bill

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COST OF LIVING

What is considered a good salary in Paris?

The higher-paying jobs are heavily concentrated in the French capital, but set against that is the high cost of living - especially the cost of renting or buying a home. So what is considered a 'high-earner' in Paris?

Published: 25 June 2024 16:51 CEST
What is considered a good salary in Paris?

Centrist Renaissance candidate Sylvain Maillard, running for re-election in France’s snap parliamentary elections, was trying to highlight the high cost of living in the capital in a debate on RMC Radio 

“You have extremely expensive rents [in Paris], between €1,500 and €1,700, and then there are all the charges and taxes to pay,” he said.

But what most people seized on was his comment that anyone earning €4,000 a month after tax would not be considered rich in Paris – he predictably was accused of being out of touch with French people’s lives.

There’s no doubt that €4,000 a month is good salary that most people would be happy with – but how much do you need to earn to be considered ‘rich’ in Paris?

National averages

Earlier this year, the independent Observatoire des Inégalités calculated poverty and wealth levels in France.

READ ALSO How much money do you need to be considered rich in France?

According to its calculations, to be considered ‘rich’ in France, a single person with no dependants needs to earn more than €3,860 per month, after taxes and social charges. Around eight percent of single workers have this sum deposited into their bank balance every month, it said.

A total of 23 percent of workers take home €3,000 or more every month, while the top 10 percent clear €4,170. 

To be in the top one percent of earners in France in 2024, one person must bring in at least €10,000 per month. After taxes and social charges.

The median income – the median is the ‘middle value’ of a range of totals – of tax households in mainland France is €1,923 per month after taxes and social charges, according to INSEE 2021 data, which means that a ‘rich’ person earns about twice as much as a person on the median income, according to the Observatoire.

Paris situation

About 75 percent of people living in Paris earn less than €4,458 per month, according to Insee data – so according to those calculations, 25 percent of Parisians earn the equivalent of the top 10 percent in France. 

But that city-wide average still hides a wide degree of variation. In the sixth arrondissement, the median income is €4,358 per month, after tax. In the seventh, it’s €4,255.  Further out, those bringing home €4,600 a month in the 19th and 20th arrondissements are among the top 10 percent in wealth terms.

But still, the median income in Paris is €2,639, significantly higher than the €1,923 France-wide median.

That would mean – using the Observatoire des Inégalités’ starting point for wealth – that a Paris resident, living on their own, would have to bring home €5,278 per month to be considered ‘rich’. 

France is a heavily centralised country, with many of the highest-paying industries concentrated within the capital, meaning there is much more opportunity to secure a high-wage job if you live in Paris.

Cost of living

Even these figures should all be taken with a pinch of salt because of the relatively high cost of living in the capital, compared to elsewhere in France. Paris is objectively an expensive place to call home.

In 2023, France Stratégie published a report on the disposable income of French households, after housing, food and transport costs were deducted. It found that, on average, people living in the Paris region had more left to spend, due to higher incomes and despite the fact that housing costs more.

It’s the income paradox in action. A person with a take-home salary of €4,000 per month has more money to spend if they live and work outside Paris. But they’re much more likely to earn that much if they live and work in Paris, where it’s not as valuable. 

Someone who earns a ‘rich-level’ salary in Paris might not appear rich – because they live in an expensive area, and a surrounded by very wealthy people in property that’s out of reach all-but the fattest of wallets. But they’re still earning more than twice the median income in France.

And that’s what Sylvain Maillard was getting at, clumsily as he may have expressed it.

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