UK
US
French-compliant assurance vie
Assurance vie is a life-insurance savings contract with its own French tax and succession treatment. The investment assets sit within the contract, and withdrawals are assessed under rules that depend on factors including contract age, premiums and the timing of payments.
A foreign bond should be reviewed against the relevant French rules before it is treated as assurance vie. Local recognition, reporting, insurer arrangements and investment restrictions matter. Fees and access also need comparing with a straightforward investment account.
Country facts to keep in view
- Personal income tax
- 0–45% + possible high-income leviesProgressive household income tax; high-income contributions and other charges can apply.
- Company tax
- 25% standardQualifying small companies may have a 15% band; large-company surcharges and special rules differ.
- Dividend tax
- Usually 31.4% combined flat tax12.8% income tax plus 18.6% social charges under current rules. Progressive-rate elections and social exemptions can change this.
- Foreign pension tax
- Ordinary income-tax rates; treaty dependentPension type, treaty exemptions or credits and social-security affiliation can affect both income tax and charges.
A situation worth reviewing
Someone moving with an existing offshore bond should obtain its policy terms and payment history before surrendering or adding money. A review can establish how France classifies it and whether retaining, adapting or replacing it would be beneficial after any tax and costs.
Assurance vie withdrawals and pension income
Assurance vie can be a topic for retirement cash-flow planning because withdrawals combine capital and investment gains. It should be considered alongside pension income, available allowances, social charges and the household's need for accessible money.
Keep the existing pension analysis separate. A UK pension's tax-free treatment in the UK does not determine the French treatment, and government-service or state payments can have distinct treaty rules. Beneficiary clauses and a surviving partner's access deserve the same attention as the withdrawal tax.
Income today, flexibility tomorrow
A retired couple could compare meeting spending from regular pension income with a combination of pension payments and contract withdrawals. The useful comparison is the household result after tax, charges and fees, rather than the tax rate of a single product.
For UK assets and UK connections
List the ISA, brokerage account, pensions and any onshore or offshore bond separately for the French review. Preserve policy and premium records before a surrender. The UK–France convention distinguishes pension categories, and the UK tax-free description of an account or payment does not establish its French treatment.
For US persons
France’s treaty provisions for recognised US pensions require an account-specific review. Keep traditional IRA, Roth and 401(k) records distinct. Assurance vie or another overseas investment contract also needs a US classification and PFIC assessment before purchase; French recognition alone is insufficient.
Before changing an arrangement
Obtain the actual contract, premium dates, withdrawal history and beneficiary clause before comparing assurance vie with a foreign bond. Review French reporting and any surrender consequence alongside fees and investment access. A trust adds a separate French reporting and legal assessment, rather than serving as an automatic alternative to a savings contract.
YOUR EXISTING ASSETS
How could your accounts fit?
Open the accounts you hold. These are starting points for a review, with the conditions and evidence attached to each finding.
UK accounts
UK ISA! High priority
The ISA exemption does not travel automatically
French tax residence brings a separate assessment of income and gains inside a UK ISA.
An ISA can keep UK relief while losing the intended shelter in France. Foreign-account declarations are a separate obligation even when no withdrawal is planned.
Worth exploring: Compare retaining the ISA with a locally recognised arrangement before selling.
Ask a planner: Which ISA income, gains and account declarations would I report?
Sources & conditions
Checked 2026-10-19. Conditions apply; no personal eligibility decision.
General investment account! Review / opportunity
Plan French tax around income and disposals
A UK brokerage account does not shelter portfolio returns from French assessment.
Separate dividends, interest and realised gains, including treaty credits and applicable social charges. Account location does not replace acquisition records or French declarations.
Worth exploring: Review a French-recognised assurance vie only after costs and tax connections are checked.
Ask a planner: Would a different withdrawal plan or recognised wrapper improve the position?
Sources & conditions
Checked 2026-10-19. Conditions apply; no personal eligibility decision.
UK pension / SIPP! Review / opportunity
UK pension income and lump sums need separate care
The UK-France convention generally allocates private employment pensions to residence, with different government-service rules.
UK tax-free treatment does not establish French exemption. Confirm the payment category, reporting and applicable social charges before taking a large sum.
Worth exploring: A coordinated withdrawal plan may help while retaining the UK pension.
Ask a planner: How will France treat my regular payments and planned lump sum?
Sources & conditions
Checked 2026-10-19. Conditions apply; no personal eligibility decision.
UK onshore bond! High priority
A UK bond is not automatically French assurance vie
A UK insurer and UK tax credit do not establish eligibility for French insurance-contract relief.
Check the contract, insurer jurisdiction and premium dates. BOFiP places conditions on foreign-contract allowances; annual foreign-policy reporting can also apply.
Worth exploring: Compare keeping the contract with an appropriate recognised alternative after exit costs.
Ask a planner: Is my UK policy recognised, and what relief is actually available?
Sources & conditions
Checked 2026-10-19. Conditions apply; no personal eligibility decision.
Offshore investment bond! High priority
The insurer and contract determine French recognition
Offshore does not mean French-compliant. Some foreign contracts qualify for particular reliefs and others may not.
The EEA conditions in BOFiP are relevant to specified allowances, not blanket exemption. Review withdrawals and disclosure before assuming the UK deferral rules apply.
Worth exploring: A recognised assurance vie is a review option rather than an automatic replacement.
Ask a planner: Does this specific policy qualify for French treatment throughout the planned withdrawal?
Sources & conditions
Checked 2026-10-19. Conditions apply; no personal eligibility decision.
UK operating business! High priority
Working from France can change the business picture
Running a UK business from France raises questions beyond the shareholder’s personal move.
Map management, premises and contract authority against UK company residence and the treaty’s permanent-establishment rules. Salary and dividends are separate personal-income streams.
Worth exploring: Review the operating arrangement before adding a foreign holding company.
Ask a planner: Where will the company be managed and the work performed?
Sources & conditions
Checked 2026-10-19. Conditions apply; no personal eligibility decision.
US accounts
401(k)! Review / opportunity
Qualifying US pension payments have a specific treaty route
Amended Article 18 generally gives the US the taxing right over payments from qualifying US pension plans.
Confirm plan eligibility, the exact distribution and the French reporting needed. The provision covers pension treatment rather than ordinary brokerage returns.
Worth exploring: The existing US plan may already provide valuable treaty treatment.
Ask a planner: Does my employer plan and planned distribution meet Article 18?
Sources & conditions
Checked 2026-10-19. Conditions apply; no personal eligibility decision.
Traditional IRA! Review / opportunity
Confirm IRA treatment before a rollover or withdrawal
The France protocol explanation includes individual retirement arrangements in its pension discussion.
Check the plan and distribution, including lump sums, against Article 18. A transfer to a foreign pension does not inherit the US plan’s treatment automatically.
Worth exploring: Compare the current IRA with alternatives before moving the money.
Ask a planner: Will retaining this IRA preserve the relevant treaty treatment?
Sources & conditions
Checked 2026-10-19. Conditions apply; no personal eligibility decision.
Roth IRA! Review / opportunity
Roth recognition deserves an account-specific check
The Treasury explanation expressly identifies Roth IRAs within the individual retirement-plan discussion.
Article 18 and the US qualification of the payment need checking together. Confirm French reporting; conversions require separate advice.
Worth exploring: Keeping a qualifying Roth can be more useful than buying a new local product.
Ask a planner: Does this payment qualify while preserving the US Roth exemption?
Sources & conditions
Checked 2026-10-19. Conditions apply; no personal eligibility decision.
US brokerage account! High priority
Brokerage returns do not receive pension treatment
French investment assessment and US reporting apply separately from Article 18 pension provisions.
Review treaty credits, income categories and social charges. Assurance vie or French funds need a US classification and PFIC review before purchase.
Worth exploring: Review the combined result before changing the existing brokerage portfolio.
Ask a planner: Which holdings work for both my French and US position?
Sources & conditions
Checked 2026-10-19. Conditions apply; no personal eligibility decision.
International structures & other assets
International trust! High priority
French trust reporting is a priority review
France has dedicated trust declarations. An international trust should not be presented as a standard French tax shelter.
The deed, roles and distributions require personal review. US connections may add foreign-trust reporting, with exceptions that must be checked. No tax saving is calculated here.
Worth exploring: Review the existing deed before making distributions or adding another trust.
Ask a planner: Who controls the trust and who can receive its benefits?
Sources & conditions
Checked 2026-10-19. Personal review only.
International pension / QNUPS! High priority
An international pension needs scheme recognition
QNUPS, QROPS and other foreign pension labels do not establish the destination’s tax treatment.
The scheme’s jurisdiction, funding, access rules and recognition must be checked. US owners can face foreign-trust and reporting questions. No numeric saving is calculated.
Worth exploring: Compare the existing pension and portfolio before paying for another scheme.
Ask a planner: Does the exact scheme and planned payment qualify in every relevant country?
Sources & conditions
Checked 2026-10-19. Personal review only.
Overseas holding company! High priority
Review the company and its owners separately
A foreign holding company does not establish residence, treaty entitlement or tax-free distributions.
Management, activity, ownership and local classification need personal review. US connections can add foreign-company and reporting obligations. This tool does not model company or shareholder tax.
Worth exploring: Review the present structure before adding administration and costs.
Ask a planner: What genuine purpose and operating substance does this company have?
Sources & conditions
Checked 2026-10-19. Personal review only.
Other / overseas asset! Review / opportunity
Bring this account into a personal review
This account is visible in your map but is outside the supported tax assessment.
Its legal form, jurisdiction and owner determine the answer. We do not infer pension, insurance or investment relief from an unfamiliar account name.
Worth exploring: A planner can review the actual arrangement alongside the rest of your map.
Ask a planner: What documents would help a planner classify this account?
Sources & conditions
Checked 2026-10-19. Personal review only.
BRING THESE QUESTIONS
Make the conversation useful.
- Does my existing bond qualify for the French treatment I expect, or should I consider another arrangement?
- How should pension payments and assurance vie withdrawals work together for our household?
- What would change if I moved again or returned home?
YOUR NEXT STEP
What would this mean for you?
Discuss your France plans, existing assets and cross-border tax questions with an International Wealth Planner.
Sources, dates and scope
Published 2026-10-19; editorial review 2026-10-26. The country fact check date is shown beside the facts. General education from an unregulated publisher and introducer. This article does not determine suitability or provide personal financial, tax or legal advice.
French assurance vie and PEA guidanceTax on assurance vie withdrawalsPUMA public healthcareForeign pension taxCompany taxDividend taxUK residence and foreign incomeUS citizens and resident aliens abroadIRS Form 8621 and PFIC reportingFrench Tax Administration: fiscal domicileFrench Interior Minister: visitor status and teleworkFrench Tax Administration: returning without French interestsBOFiP: foreign life-insurance proceedsFrench Tax Administration: trust reportingHMRC: UK–France conventionUS Treasury: French pension Protocol explanationOur editorial standards