Brexit Didn’t End UK–France Tax Problems – It Changed Them
Sunday, 15 March 2026
Brexit has transformed, rather than resolved, the tax challenges facing UK nationals with French assets, income or relocation plans, according to France Tax Law, the London-based French notarial practice specialising in French tax, property and succession matters. The firm reports a steady rise in post-Brexit cases where UK residents with French connections have misunderstood how residency, social charges and filing rules now interact between the two countries.
Brexit has changed, not removed, tax risks
For individuals with homes, investments or business interests in France, Brexit has sharpened the distinction between UK and French tax residency, with French rules looking at factors such as main home, principal professional activity, days spent in France and where most income arises. While non-residents are still taxed only on French-source income, the practical application of the UK-France double tax treaty has become more complex as people's working patterns and living arrangements have changed since Brexit.
“The UK-France double taxation agreement still prevents the same income being taxed twice in principle, but the way it applies now depends very closely on where you actually live, work and hold your assets,” says a spokesperson for France Tax Law.
“Post-Brexit, small changes in a client's lifestyle - from hybrid working to spending longer periods in a French holiday home - can have significant tax consequences on both sides of the Channel.”
Social charges and French property in focus
A key area of confusion is French social charges on income and gains linked to French assets. Post-Brexit, UK nationals who are not affiliated to an EU social security system may be more exposed to French social charges on certain categories of French-source income than they were as EU citizens, depending on their precise situation.
French property continues to create complex interactions between income tax, capital gains tax and social surcharges, particularly where a UK resident owns, rents out or sells French real estate. Higher-value portfolios can also fall within the scope of France's real estate wealth tax (Impôt sur la Fortune Immobilière), which requires careful monitoring and planning for UK residents.
“Many British owners of French property assume that if they remain a UK resident, nothing has really changed for them after Brexit,” the France Tax Law spokesperson adds. “In reality, the mix of income tax, capital gains tax, social charges and, in some cases, real estate wealth tax can be quite different in the post-Brexit era and needs to be reviewed regularly.”
Filing and compliance obligations
France continues to place significant emphasis on clear classification as tax resident or non-resident, and non-residents with French-source income must still file French tax returns and comply with local reporting obligations. UK nationals moving to or from France - or splitting their time between the two - must co-ordinate French and UK filings so that income, gains and assets are declared in the correct jurisdiction and treaty relief is claimed where appropriate.
France Tax Law assists clients with French income tax returns, inheritance tax forms, trust declarations and related compliance, helping cross-border families and entrepreneurs avoid common post-Brexit filing errors. The firm warns that failing to align UK and French filings, or assuming that UK treatment automatically carries across to France, remains one of the most frequent and costly mistakes.
France Tax Law's perspective
Based in London, France Tax Law brings together French-qualified notaires with experience in French and European notarial law, covering tax, property, succession, family and business law for UK-connected clients. With over two decades of combined notarial and international practice experience, the team is used to translating French legal and tax concepts for UK audiences and liaising directly with French authorities and professionals on their behalf.
“Brexit has made bespoke, fact-specific advice more important than ever,” the spokesperson concludes. “You cannot look at UK and French tax in isolation: residence, treaty interaction, future relocation plans and family succession objectives all need to be considered together if you want a robust, future-proof cross-border strategy.”