Being a UK director of a Ltd Company but living in France

Hmm, News to me, sounds good - no corporation tax on first 11K -in fact sounds too good to be true…

…and it was.

First 12570 of personal income can be tax free though - if earned in UK of course, not UK.

Interesting question and Polite thought - why wouldn’t all French entrepreneurs be setting up UK companies instead of the French equivalent?

Thinking further, the company would have to pay the UK company maintenance fees etc, the French employer taxes and the company maintenance overhead - not massive, granted. You might benefit through dividends - but 19% corporation tax and then whatever France tax on dividends on top - don’t know. And as you mention, small earnings whether company or self employed… you could do the numbers if you check out the sites and the rates?

And mind you, paying the appropriate level of ‘UK salary’ would give you a years UK pension credit - there’s been threads here about whether the France pension system is less ‘benefiting’. And it would be interesting whether the UK company salary wouldn’t count for a pension credit if you lived in France - I haven’t seen anything which suggests otherwise.

I wish you good luck in your endeavours, decisions eh… :slight_smile:

Dear Larkswood, thank you for your kind message…I love this site.
I booked a meeting with a french accountant and he will explain everything to me…he deals with this sort of scenario all the time and most interesting he has a uk limited company for a separate business while he lives in France so will be an interesting chat lol.
Thank you for your message again

Also even if there are benefit having a uk limited company, well most people from France wouldn’t know unless they lived in uk and if you did not i guess would take too much time and effort to understand…people always feel safe to do things back home obviously.
Thank you

Thank you

Please let us know what the French accountant says @Pat99. This could be highly interesting

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Absolutely but like Ben says we can get different opinions from various accountancy firms so anyone here should look carefully before making any decisions.
I think for small earners not worth it to keep a uk limited company and possibly better to start a new one here or just register as a solo trader i think but for anyone with high earning ( sadly not my case lol) worth too look into it…Amazon and Starbucks are the proof lol
Thank you Karen for your message

Hey Pat, did you have any updates / info from the french accountant you spoke to? Still a bit in the dark as to what to do to be totally honest!

Isn’t it also that when you have a UK company but the actual admin is done from France, according to the EU law this UK company is considered to be domiciled in France and has to pay also its corporate taxes in France, not in UK?

For example, in Germany, this is the case and — because there’s no separate agreement between UK and Germany — they would also treat this UK Ltd not as a company but as a person (sole trader) in their law, which implies even higher rate of tax as you have to pay not only the profit tax in Germany but also the social contributions.

Can somebody elaborate if it’s the same in France?

Hello to all! I would like to know what the accountant with a UK LTD company said. I am the owner of a LTD non-resident company in the UK. Just arrived in France and had a daughter (I am Mexican and my wife is French).

Following extensive and thorough research, I am sure that I am not required to pay personal taxes in the UK. Instead, I need to pay taxes both for my LTD and personally in France.

I am in the how to pay taxes in Franse phase … Weird situation because I have my books in UK and in English…

Some articles related to the subject:

INTM120070 - Company residence: 'Treaty non-resident' companies - HMRC internal manual - GOV.UK
Change of view on the interpretation of the residence articles in sixteen Double Taxation Agreements - GOV.UK

Please, if anyone has an advise let me know.

Hello, go and see your local hôtel des impôts. Go with your wife as she is French she should know about it and be able to help you, you will be taxed as a unit anyway.

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@Pat99 What did that French accountant with a UK ltd accountant say? And if possible if they were good I would love to get their details and know their price. Thanks so much for any and all feedback. Best, Andrea.

@benmeaker @Pat99 . One year later almost, for the love of the God of Croissants, did you guys survive this and got any clarity on this in the end, if so, could I beg you to share how? I am almost crying with hysterical relief at, at least, having found these useful posts. The contradictions in professional accountancy firms advice both in France and UK plus the overload of inconsistent information with automated boxes missing the ones that fit my scenario is driving me nuts! I am French (sorry, our bad), director of a small UK cie ltd by guarantee, so exactly the same issues as you, with the added fun of being non profit meaning I risk losing a 3 year grant cycle of funding if I took options to restart a company, and my funding contracts cannot be legally transferred to a French branch even if i did have the money to register. AAAAAAAAAAAaaargh. Hoping to see a new post appear, as I write this, I hope that you both made it and are having a lovely ‘jour férié’ in a nice beach restaurant.

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Hi I came across this thread and was wondering if anybody has any updates as I am in a very similar position (I realise it is a bit cold - but I post in hope!)

Interesting thread… I have a number of clients that have Ltd co in the UK.

They don’t take any money from the UK company in dividend or income.

One is a ME and invoice’s to the UK Ltd company for work carried out. (The other has a SASU as the amounts are more)

This makes it a deductible company expense in the UK for the invoice for consultancy.

All invoices paid to the ME in France are declared through URSSAF taxed and social charged. (Or as the SASU)

As the ME and SASU both invoice direct to clients as well as the UK company it satisfies the rules for IR35 in the UK which protects contractors from being exploited.

If the company in the UK just invoices to France it will be only conducting business in France and then should have a French office. So as long as business is being done from the UK to other UK and non French companies then there isn’t a need to have a French shell company.

I didn’t give this advice personally as I am not an accountant but this process has been in place for a number of years and no issues… but as always you should get personal advice from someone regulated in the jurisdiction.

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Just FYI, The UK company could pay into a directors personal pension plan and when that is cashed in fully in one go the incomewould be eligible for the France flat 7.5% rate? Presume that strategy depends on your clients ages and when and how much they need the money from the company?

  • no intention to teach sucking eggs etc :slight_smile:
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Interesting thread.

I am retired living in France with my wife on an S1 with my wife on a dependant S1. Although she will get her UK state pension and an S1 in her own right next year. In order to stop paying social charges on her UK uni pension she had to “Radiate” herself as an ME. Ie give up being an ME.

We have a UK Ltd company and make a few thousand a year renting software and providing consultancy services. Our daughters are shareholders although they have other full time jobs.

I see that with a UK Ltd company you can pay from retained profits a shareholders dividend of £500 with no UK tax implications ( Not necessary to declare this as extra earnings to the IR.

What would be the French tax implications if we paid ourselves £500 each.?

Declaration of Worldwide Income… is just that…
So all monies are declared in France and will add up …to the total income figure.
Once French Tax folk have deducted whatever Personal Allowances they deem suitable from this total figure… you will be left with the figure on which French Tax is calculated (if necessary) … and whatever Tax has been paid in UK will be deducted from whatever Tax France reckons you owe 'em.

If France reckons you don’t owe 'em any Tax… all well and good… but don’t ask 'em to refund anything you might have paid in UK…

I think this is a simplified version of what happens… others with more knowledge will chime in…

I found this online

As we are exempt from social charges through our S1s I suppose we would just have to pay the 12.8% tax element.

Rgds Nick