The 2008 UK-France Double Taxation Convention, in force from 18 December 2009, allocates taxing rights on UK property to the UK as situs state. So far, so OECD-standard. The complications for a UK-French landlord sit outside that framework. French social contributions (CSG and CRDS) add about 17.2% to French income tax on rental income for French residents. The French real estate wealth tax (IFI) applies to UK property held by French residents above €1.3 million net. And the 1963 UK-France IHT treaty sits as a separate document, still in force, that the new UK residence-based IHT regime from April 2025 maps onto awkwardly. This page walks through the treaty mechanics in both directions, then the French-specific overlays that landlords on either side of the Channel need to plan against. For the OECD framework that sits underneath this page, see our [UK tax treaties framework guide](/blog/non-resident-landlord-tax/tax-treaties-property-investors-treaty-framework-guide). ## The 2008 UK-France treaty in 2026/27 The current UK-France treaty was signed on 19 June 2008 and entered into force on 18 December 2009. It replaced the older 1968 convention. The 2008 treaty broadly follows the OECD Model with the standard French articles, with one peculiarity in numbering: capital gains sit at Article 14 (not Article 13 as in the OECD Model), elimination of double taxation sits at Article 24, and the social-security article sits at Article 19. House-position citations in this guide track the treaty article numbers, not the OECD Model numbers. Two general points before the article walk: - **Multilateral Instrument (MLI).** Both the UK and France have ratified the MLI, which modifies the 2008 treaty in several places (notably the principal purposes test under MLI Article 7 and the dual-resident-person provisions). Always read the synthesised text on the gov.uk France hub or on the OECD MLI synthesis tool, not the original 2008 treaty alone. - **Post-Brexit position.** The income tax treaty is unchanged by Brexit. EU-derived case law on social contributions (de Ruyter, Jahin) is no longer binding on the UK as a third country. The CSG/CRDS position for UK-resident landlords with French rental has been unstable since 1 January 2021. ## Article 6: UK rental income stays with the UK Article 6 (immovable property) gives the UK primary taxing rights on UK rental income. A French-resident landlord with a Brighton flat pays UK income tax on the Brighton rent under ITTOIA 2005 Pt 3, regardless of French residence. The s.272A finance-cost restriction (the section 24 mortgage interest restriction) applies as for any UK-resident individual landlord. The £12,570 personal allowance is available where the landlord is a UK or EEA national or qualifies under the treaty's non-discrimination article (Article 4 of the 2008 treaty). The French side then layers on top. France taxes its residents on worldwide income (impôt sur le revenu) and gives credit for UK tax paid under the treaty's Article 24 elimination-of-double-taxation article (tax-credit method on UK property income). France then adds the CSG/CRDS social contributions to the post-credit income tax, with the CSG/CRDS sitting outside the treaty's coverage. ## Article 24 elimination: the French tax credit method Article 24 of the 2008 treaty sets out the methods by which the two states eliminate double taxation. For UK property income paid to a French resident, France uses the tax-credit method: - France taxes the UK rental income as part of the French resident's global taxable income. - France grants a credit equal to the UK income tax paid on the same income, capped at the French tax that would otherwise be due on that income. - Where the UK tax exceeds the French tax on the same income, the excess is generally unrelieved (no carry-forward). The credit operates net of any UK personal allowance the landlord claims. A French-resident UK national with a £14,000 UK rental profit and £12,570 personal allowance pays UK income tax of about £286 (20% on the £1,430 above allowance, before s.24 adjustments). The French credit is restricted to that £286 against the French tax on the same income. France then applies the marginal French rate (potentially much higher) on the post-credit base. In the reverse direction (UK-resident landlord with French rental), the UK as residence state taxes the French income and credits the French income tax paid. The credit goes on the foreign pages (SA106). Note: CSG/CRDS suffered by the UK resident is generally not creditable in the UK because it is a social contribution rather than a foreign income tax, though see the FAQ note for the unsettled post-2018 case law position. ## The CSG/CRDS overlay: where the treaty stops CSG (Contribution Sociale Généralisée) and CRDS (Contribution au Remboursement de la Dette Sociale) are the two principal French social contributions on investment income. For French residents with rental income (UK or French source), the combined rate is approximately 17.2% in 2026 (CSG 9.2% + CRDS 0.5% + prélèvement de solidarité 7.5% on investment income; rates change frequently in successive Loi de Finances cycles). Three points UK-French landlords routinely miss: 1. **CSG/CRDS is outside the income tax treaty in its strict form.** The 2008 treaty covers income tax (impôt sur le revenu) and corporation tax (impôt sur les sociétés). It does not list CSG/CRDS as a covered tax in Article 2. France can levy CSG/CRDS on a French resident's UK rental income without violating treaty obligations on UK income tax allocation. 2. **The post-de-Ruyter EU position no longer constrains the UK side after Brexit.** Pre-2018 CJEU case law (de Ruyter, then Jahin) held that France could not levy CSG/CRDS on EU-residents covered by another EEA social security regime. The UK left the EU on 31 December 2020. A UK-resident landlord with French rental can no longer rely on de Ruyter to displace French CSG/CRDS on the French rental income. 3. **UK foreign tax credit on CSG/CRDS is contested.** HMRC's published position treats CSG/CRDS as social contributions outside the scope of UK foreign tax credit relief. Some practitioner-side arguments hold that the post-de-Ruyter "tax in substance" reasoning supports partial relief. In practice, build the model assuming the bulk of CSG/CRDS is unrelieved on the UK side. ## Article 14: capital gains on UK property Article 14 (capital gains) of the 2008 treaty gives the UK primary taxing rights on UK immovable property gains (paragraph 1) and on shares in property-rich entities (paragraph 4). The treaty allocation is consistent with current OECD practice. For a French-resident disposal of UK property: - **UK side:** Non-Resident CGT applies under [TCGA 1992 s.1A and Schedules 1A, 1B, and 4AA](/blog/non-resident-landlord-tax/non-resident-cgt-uk-property-rates-reporting). The 60-day UK property return is required regardless of tax due. Rate: 18% basic / 24% higher on residential gains from 30 October 2024. Rebasing options to 5 April 2015 (residential) or 5 April 2019 (non-residential) generally favour the seller. For the operational walkthrough, see our [non-resident CGT selling guide](/blog/non-resident-landlord-tax/non-resident-cgt-selling-uk-property-overseas-guide). - **French side:** France computes a plus-value immobilière on the same disposal under French rules. The base differs from UK base: French rules allow indexation of acquisition cost in certain cases and a taper relief by length of ownership (full exemption from French income tax after 22 years' ownership; full CSG/CRDS exemption after 30 years). Standard French rate: 19% income tax + 17.2% CSG/CRDS, with taper relief reducing the base on each side over time. - **Credit on the French side:** UK CGT paid is creditable against French income tax on the same gain under Article 24. CSG/CRDS portion is not offset by UK CGT credit (because UK has no equivalent social-contribution layer to credit-mirror). The cross-border CGT calculation is therefore highly sensitive to length of ownership. A 30-year-held UK property sold by a French resident may produce a substantial UK CGT line (no taper on the UK side) but no French tax (full taper on the French side); the UK CGT becomes the only tax line. A 5-year-held property may produce UK CGT plus a significant French income-tax-net-of-UK-credit plus a full CSG/CRDS line. ## IFI: French wealth tax on UK property The Impôt sur la Fortune Immobilière (IFI) is a French wealth tax on real estate, introduced in 2018 as a successor to the older ISF (Impôt de Solidarité sur la Fortune, abolished except on real estate). IFI applies to French tax residents on worldwide real estate assets where the net value exceeds €1.3 million on 1 January each year. For a French-resident UK landlord: - **UK property is within the IFI base.** Both directly held and structures (SCI, foncier company shares above the property-rich threshold) feed the base. - **Rates rise from 0.5% to 1.5%** across six bands above the threshold (band breakpoints around €800k, €1.3m, €2.57m, €5m, €10m). - **Net of mortgage debt:** mortgage borrowing on the UK property is generally deductible from the IFI base, subject to anti-avoidance rules for related-party debt. - **No UK equivalent to credit:** the UK has no wealth tax, so the credit-method machinery in Article 24 produces no offset. IFI is the wealth-tax equivalent of the CSG/CRDS line on income: outside the treaty perimeter, no UK offset, and material on portfolio-scale UK holdings. A French resident with three UK BTL properties worth £2 million each (£6 million total, around €7 million depending on the cross rate) sits well into the IFI bands. A €5 million net base attracts roughly €30,000 a year in IFI. ## Two scenarios: which side are you on? **Scenario A: French-resident landlord with UK property.** UK income tax on rental under Article 6. NRL withholding statutory (apply for NRL1 gross approval). UK NRCGT on disposal under Article 14. French income tax with UK credit under Article 24. CSG/CRDS layered on top, no UK offset. IFI on UK property in the French wealth tax base if total net real estate > €1.3 million. **Scenario B: UK-resident landlord with French property.** France retains primary taxing rights on French rental and gains under Articles 6 and 14. UK as residence state taxes the foreign income on SA106 with foreign tax credit for French income tax (under TIOPA 2010 + Article 24). CSG/CRDS suffered by UK resident (where it applies to non-resident) generally unrelieved on the UK side. No UK wealth tax to mirror IFI. The compliance load is asymmetric. Scenario A has a relatively heavy French side (income tax + CSG/CRDS + IFI + IFI annual return) and a relatively standard UK side. Scenario B has a relatively standard UK side (SA106 + foreign tax credit) and a relatively standard French side from the UK landlord's perspective (form 2042 + 2044 if elected for the régime réel; or microfoncier for low-rent profiles). The traps in Scenario B are around French succession rules and forced heirship, not the income tax treaty. ## Worked example: Brighton landlord moving to Lyon Pierre is a French national, UK-resident from 2018 to 2025/26, with a single-let Brighton flat acquired in 2019 for £290,000 (financed with a £203,000 interest-only mortgage). Rent £19,200 gross, agent-managed, current value about £330,000. Pierre moves to Lyon on 6 April 2026 and is French tax-resident from that date (SRT outcome: non-UK-resident for 2026/27 onwards). **UK side, 2026/27.** - Pierre is non-UK-resident. NRL scheme applies. Pierre applies for NRL1 in March 2026; HMRC approves in May 2026. From the May approval, rent flows gross. - Rental profit: £19,200 less agent commission, repairs, insurance ~£3,400 = £15,800 (mortgage interest of ~£5,500 added back per s.272A). - Pierre is a French national. UK personal allowance available under the UK-France treaty non-discrimination provisions: confirm under HS304. Assume yes. - UK income tax: £15,800 less £12,570 = £3,230 taxable at 20% = £646. Section 24 credit: 20% of £5,500 = £1,100, capped at 20% of rental profit before s.24 (£21,300) = £4,260 cap, so the £1,100 is fully usable. Credit reduces UK income tax to nil; £454 of unused credit carries forward. **French side, 2026/27.** - Pierre is French tax-resident from 6 April 2026. He files a French 2042 (impôt sur le revenu) including UK rental income. - French rental income computed under French rules (régime réel for unfurnished long-let, accruals basis with French expense deductibility). Approximately €17,500 net rental profit (cross-rate dependent). - French income tax: marginal rate (Pierre's other income brings him into the 30% French band). Tax on the UK rental at 30% = ~€5,250. - UK income tax credit under Article 24: nil (because Pierre paid no UK income tax after s.24 credit). - CSG/CRDS 17.2% on the net rental: ~€3,010. No UK offset. - IFI: Pierre's UK property worth around €380,000 plus his French primary residence (€600,000 net of mortgage) totals about €980,000. Below the IFI €1.3 million threshold. No IFI in 2026/27. **Net cost of moving:** Pierre's UK tax is about the same as before (nil after s.24 credit, by happy coincidence). His French income tax on the UK rental is around €5,250 a year. His CSG/CRDS is around €3,010 a year. He has gone from a single UK income tax line (~£3,000 a year on equivalent profit while UK-resident) to a combined French line of around €8,260, a net increase of approximately €5,000 a year. Disposal will trigger UK NRCGT plus French plus-value with credit and CSG/CRDS layers. The arithmetic is illustrative; specifics depend on currency rates, French income tax bands in the relevant year, and any structuring (e.g. holding through an SCI for forced-heirship reasons, which changes the IFI and succession picture materially). ## The UK-France IHT treaty (1963): the lesser-known overlay The 1963 UK-France Convention on the Avoidance of Double Taxation with Respect to Duties on the Estates of Deceased Persons sits separately from the 2008 income tax treaty. It is still in force. The 1963 treaty allocates IHT taxing rights between the UK and France on a cross-border estate. Key provisions: - **Real property situs rule:** the situs state (where the property is located) has primary taxing rights on real property duties. - **Domicile articles:** the original treaty uses a domicile concept that maps awkwardly onto the new UK residence-based IHT regime from 6 April 2025 (long-term-resident test: 10 of preceding 20 tax years). Treaty interpretation arguments are likely in early cases that span the transition. - **Credit mechanism:** the domicile state credits the situs state's duty. For a UK-domiciled (or now, long-term-resident) individual with French property, the UK gives credit for French succession duty. For a French-domiciled landlord with UK property (or a UK long-term-resident landlord with French property), the 1963 treaty interacts with the broader 2025 reforms. Forced heirship under French law (réserve héréditaire) further complicates the picture for individuals who would prefer English freedom of testation; the EU Succession Regulation 650/2012 (Brussels IV) provides a choice-of-law election in the will, but the post-Brexit position for UK persons is more complex than for EU nationals. This page does not attempt a full IHT walkthrough; the [UK inheritance tax on rental property guide](/blog/landlord-tax-essentials/inheritance-tax-rental-property-uk-guide) covers the general UK position. For cross-border cases, get specialist advice on both sides of the Channel. ## Compliance: HS304, SA106, NRL1, 2042-NR, IFI return The UK-French landlord runs annual returns in both jurisdictions. **UK side (Scenario A, French-resident landlord with UK property):** - NRL1 application to receive rent gross (one-off, lapses if circumstances change). - UK self-assessment annually, by 31 January following the tax year (paper deadline 31 October). Property pages (SA105) for the UK rental. - HS304 claim for treaty-based UK relief (e.g. personal allowance under non-discrimination). - 60-day UK property return on any disposal. **French side:** - Form 2042 (impôt sur le revenu) annually, with 2042-NR for non-residents in the inverse direction. - Form 2044 if régime réel elected for rental income (default for higher rents; microfoncier alternative for sub-€15,000 gross rent). - IFI return (form 2042-IFI) annually if net real estate above €1.3 million on 1 January. - French plus-value declaration on disposal (separate form). **UK side (Scenario B, UK-resident landlord with French property):** - UK self-assessment with SA106 foreign pages for the French rental. - Foreign tax credit under TIOPA 2010 ss.18 and 130 for French income tax paid. - HMRC's [HS304 helpsheet](https://www.gov.uk/government/publications/non-residents-relief-under-double-taxation-agreements-hs304-self-assessment-helpsheet) is for the inverse-direction reader, but the broader [International Manual at INTM161000](https://www.gov.uk/hmrc-internal-manuals/international-manual/intm161000) covers the UK-resident side. ## What to do next The UK-France position is more layered than the OECD Model implies. The treaty does its job on the income tax allocation; the CSG/CRDS layer is what pushes the net French tax burden well above the headline rate, and IFI on portfolio-scale UK holdings is a separate £30,000-plus annual cost. - **Confirm your scenario.** Are you Scenario A (French-resident with UK property) or Scenario B (UK-resident with French property)? The treaty mechanics apply the same way but the compliance load differs sharply. - **Get the CSG/CRDS line on the model.** Whatever the headline French income tax rate looks like, add roughly 17.2% on the net rental for a French resident, and assume no UK offset. - **Run the IFI threshold check** if your French residence move puts your worldwide real estate above €1.3 million net. - **For estates, read both treaties.** The 1963 IHT treaty + the 2008 income tax treaty cover different ground. The new UK residence-based IHT regime from April 2025 changes how the 1963 treaty applies. - **For framework context**, see our [UK tax treaties framework guide](/blog/non-resident-landlord-tax/tax-treaties-property-investors-treaty-framework-guide) and the [non-resident landlord scheme guide](/blog/non-resident-landlord-tax/non-resident-landlord-scheme-uk-complete-guide). The treaty is not the whole story for the UK-France case. Plan for the layers the treaty does not cover; the income tax allocation is the easy part.