In France, tax is due on world-wide income, whether from investments or earnings, when an individual is deemed to be tax resident. Non-residents are taxed only on French source income and assets. Tax residency is assumed if the individual has a home in France, if it is their principal abode, if it is the centre of their economic interests, or if their principal professional activities are performed there.

Liability to social security payment derive from the same principles.

Establishing non-residence usually amounts to demonstrating that residence has been established elsewhere, and that the normal tests for French residence are not fulfilled. Clearly this is not easy, and it can often happen that a foreign worker has dual tax-residence, at least for a period.

Double Tax Treaties, where they exist, usually sort this out. This is not totally the case here, hence the social security demand for payment.

http://www.solicitor.fr

Fabien Cordiez, Aix en Provence, France

Interesting article, but not very surprising as such. Quite frankly, Linklaters and others in the same situation should've seen it coming, the French welfare state organisation has been collecting left, right and centre ever since the government decided to reduce direct taxation on revenue. In fact, now that the revenue tax office and the welfare tax office work more closely together, I'm surprised it didn't happen earlier. I'm also surprised that the French government isn't trying to levvy wealth taxation (ISF) on those high earning French resident British lawyers who have bought property in France. After all, they try it on with everyone else. Of course, the classical attempt to escape taxation of that ilk was to shelter behind the double taxation agreements signed 40 years ago. Unfortunately, things have evolved somewhat since then, and as always, until the European Union can come to agreement about EU-wide taxation in general, then these issues will keep cropping up.

Alexander Thurgood, Clermont Ferrand, France

well, if they don't want to pay URSAFF then they should go back live and work in Britain. Profit is a higher value in Britain thatr social solidarity, not so in France. In Rome do as the Roman or get out

ulisse leon broglie, suva, fiji