Cross-border retirement planning is not simply retirement planning with a passport. It is a fundamentally different discipline that requires coordinating income sources, tax systems, currencies, and legal frameworks that were never designed to work together. For Americans and British expats retiring in France, the retirement picture rarely comes from a single source. It comes from several: a US 401(k) or IRA, a UK SIPP or defined benefit pension, Social Security or the UK State Pension, a French assurance vie, perhaps a French retraite pension built during working years in France, and investment portfolios that may sit in accounts across multiple jurisdictions.

The challenge is not that any one of these income streams is particularly complicated in isolation. It is that they all interact. The timing of your first IRA withdrawal affects your IRMAA Medicare surcharge two years later. The size of your SIPP drawdown determines your French income tax bracket for the year. The currency in which your pension arrives affects your real spending power in France every single month. The order in which you draw from different accounts can mean the difference between an efficient tax outcome and an avoidable double-taxation problem.

This guide maps the complete retirement income landscape for expats in France in 2026: what each major income stream is, how it is taxed on each side of the border, and how the pieces fit together into a coherent plan. None of this should be treated as a template to follow independently. Cross-border retirement planning of this complexity is exactly where a financial adviser who understands both countries delivers the most tangible value. Our US Citizens in France service page and International SIPP page explain how we approach this for each audience in practice.

The Retirement Income Map: What Expats in France Are Actually Drawing From

Before planning how income streams interact, it helps to have a clear inventory of what each audience is typically working with.

Income Source	Primarily American Expats	Primarily British Expats	Both
Social Security / UK State Pension	✓	✓
Traditional IRA / 401(k) drawdown	✓
Roth IRA (tax-free income)	✓
UK Defined Benefit pension		✓
SIPP drawdown		✓
QROPS (Qualifying Overseas Pension)		✓
French retraite (state pension)			✓
Assurance vie withdrawals			✓
Taxable investment portfolios			✓
Rental income (French or home country)			✓
US annuity income	✓

Most retirees draw from several of these simultaneously. The planning complexity compounds with each additional source, because each has its own tax treatment, its own currency, and its own interaction with the French tax return.

For American Expats: Building a Tax-Efficient Income Stack in France

Social Security: The Most Treaty-Protected Income Stream You Have

Under Article 18bis of the France-US Income Tax Treaty, US Social Security benefits paid to French residents are taxable only in the United States. France cannot impose income tax on these payments. This makes Social Security the most tax-efficient income stream available to an American retiree in France: you pay US federal tax on the applicable portion (up to 85 percent of your benefit, depending on your combined income), and France leaves it entirely alone.

What this means for sequencing is significant. Because Social Security income does not add to your French taxable income, drawing it alongside other tax-efficient sources such as Roth IRA distributions creates a retirement income stack that can be meaningfully lower in French tax exposure than drawing the same amounts from a Traditional IRA. The decision about when to claim Social Security is therefore not just a US actuarial question but a cross-border tax question, and the optimal claiming age looks different when France is in the picture.

Traditional IRA and 401(k) Drawdown: Treaty Protection With a French Dimension

The France-US treaty’s treatment of private pension and IRA income is more nuanced than Social Security. Under Article 18, distributions from qualified US retirement plans are generally taxable primarily in France once you are a French resident, with a credit mechanism to offset US tax paid. In practice, this means IRA and 401(k) withdrawals are declared on your French income tax return, taxed at French rates, and you claim a credit for any US tax withheld. The critical question is whether French income tax rates on your total income produce a higher effective rate than the US would have charged on the same withdrawal.

For most retirees, French income tax rates are not necessarily higher than US rates on moderate incomes, particularly after the standard abattements and deductions available on the French return. But the interaction with other income sources, the bracket effect, and the IRMAA surcharge timing on the US side all make this a calculation that needs to be done with specific numbers rather than general assumptions.

Roth IRA: The Tax-Free Income Stream That Works Best in France

Qualified Roth IRA distributions are tax-free in the US. Under the France-US treaty, the taxing right over US retirement distributions is allocated to the US. While these distributions are generally not subject to direct French income tax, it is important to note that France may still include this income under the “taux effectif” (effective rate) mechanism, which can impact the tax calculation on other income sources. As such, the outcome is highly dependent on an individual’s specific tax profile, and it is crucial to model these distributions alongside all other worldwide income.

There are no Required Minimum Distributions on Roth IRAs during the original owner’s lifetime, which means the account can continue growing tax-free indefinitely, with the owner controlling the timing and amount of withdrawals entirely. For anyone who converted pre-tax balances to Roth before establishing French residency, this is the long-run payoff on that planning decision. For anyone who has not yet done so and is still a US resident, the pre-residency Roth conversion window is one of the most time-sensitive and high-value decisions in cross-border retirement planning.

The IRMAA Interaction: Why Withdrawal Sequencing Matters for Medicare

For Americans who will eventually draw Medicare, a critical dimension of IRA withdrawal sequencing is the Income-Related Monthly Adjustment Amount (IRMAA). Medicare Part B and Part D premiums are surcharged for higher-income beneficiaries, assessed on income from two years prior. A large IRA withdrawal in 2026 can therefore trigger a higher Medicare premium in 2028, even if you are living in France and not actively using Medicare. This two-year lookback effect means that large one-time income events, Roth conversions, property sales, or unusually large IRA withdrawals, should be modelled against the IRMAA thresholds before they are executed, not discovered as a surprise two years later.

For British Expats: Coordinating SIPP, DB Pension, and State Pension From France

The UK State Pension: Frozen, Thawed, and Treaty-Treated

The UK State Pension is paid to eligible British nationals regardless of where they live. However, the triple lock uprating (increasing the pension by the highest of earnings growth, inflation, or 2.5 percent) applies only if you live in a country with a reciprocal social security agreement with the UK. France does have such an agreement, which means British expats in France do receive annual uprating of their State Pension, unlike those who retire to certain other countries where the pension is frozen at the rate when they left the UK. This is a meaningful long-run benefit that is often underappreciated.

Under French tax rules, UK State Pension income received by a French resident is generally treated as foreign pension income and declared on the French return, subject to French income tax after applicable abattements. The UK-France tax treaty allocates taxing rights on private pensions to the country of residence, meaning France. UK tax should not also be deducted if you have correctly registered as non-resident with HMRC and have a valid S1 form or equivalent.

SIPP Drawdown: The Investment Decisions That Drive Real Income

A Self-Invested Personal Pension (SIPP) gives the retiree direct control over both the investment strategy and the withdrawal rate in drawdown. For British expats in France, the SIPP is often the largest single source of retirement income, and the decisions made about how to invest the SIPP in drawdown are as important as the decisions about how much to withdraw each year.

In drawdown, the portfolio needs to do two things simultaneously: generate sufficient income to meet spending needs and preserve enough capital to sustain that income across a retirement that could last thirty years or more. The asset allocation for a drawdown SIPP is different from that of an accumulation SIPP, and many expats continue with the same investment strategy they used while building the pot, without ever reconfiguring it for the different demands of the withdrawal phase. A financial adviser can model the sustainable withdrawal rate, sequence of returns risk, and currency exposure specific to a French-resident retiree’s situation.

For detailed guidance on how US and UK stocks behave differently inside a SIPP and the currency considerations for British expats in France, our SIPP investment guide covers the investment strategy and platform considerations in full.

Defined Benefit Pensions: The Guaranteed Income That Still Needs Planning

Many British expats in France draw a defined benefit (DB) pension from a former UK employer. These pensions pay a fixed income for life, often with inflation linking. From a cross-border retirement planning perspective, a DB pension is a form of guaranteed income in sterling that is paid regardless of investment market performance. It provides a secure floor, but it also creates a permanent sterling-denominated income stream for someone living and spending in euros.

The currency dimension of a DB pension is one of the less-discussed risks in British expat financial planning. If sterling weakens against the euro, the purchasing power of that fixed pension income in France falls accordingly, with no mechanism for adjustment. Building the rest of the retirement portfolio around the currency exposure created by a DB pension, rather than treating it in isolation, is exactly the kind of whole-picture planning a financial adviser provides.

QROPS: Still Relevant for Some, Not for Others

A Qualifying Recognised Overseas Pension Scheme (QROPS) allows eligible British pension holders to transfer their UK pension pot into an overseas pension structure. The potential benefit for French residents is that a QROPS can be structured in euros, eliminating the currency mismatch of a sterling-denominated SIPP, and may offer different inheritance and drawdown flexibility. However, the QROPS landscape changed significantly with UK tax rule changes, and the Overseas Transfer Charge of 25 percent applies unless specific conditions are met. QROPS is not automatically the right answer. Whether it is appropriate depends on the size of the pension, the tax treatment in France, and the individual’s long-term plans. This is a decision that should never be made without specialist advice.

The French Layer: Assurance Vie, French State Pension, and French Tax

The French Retraite Pension

Americans and British nationals who worked in France during their careers may have built up entitlement to a French state pension (retraite) through contributions to the French social security system. Both the France-US and France-UK social security totalization agreements allow work credits earned in either country to count toward eligibility in the other. If you worked in France for several years and then moved to the US or UK, those French years may count toward your French pension entitlement.

A French retraite pension paid to a French resident is subject to French income tax as a pension income, with a 10 percent abattement up to an annual cap. It is also subject to the CSG and CRDS social charges. The 2026 loi de financement de la sécurité sociale raised the CSG rate on capital income, and social charge rates on pension income should be confirmed annually with a French tax adviser given the pattern of incremental changes in recent budgets.

Assurance Vie in Retirement: The Tax-Efficient Withdrawal Wrapper

French domestic assurance vie is generally not available to US citizens due to FATCA compliance complications for French insurers. For American expats, these structures often create significant reporting and tax complexities, including potential PFIC (Passive Foreign Investment Company) classification and FBAR reporting obligations, which make them unsuitable for Americans.

An assurance vie, whether a French domestic policy or a Luxembourg policy such as those previously distributed under the Lombard International or Utmost Luxembourg brands, can serve as one of the most tax-efficient income sources in a French retirement. After eight years of holding, withdrawals benefit from a tax-free annual allowance of EUR 4,600 (EUR 9,200 for couples) applied against the gains portion of each withdrawal. Only the gains element, not the return of capital, is subject to tax or the preferential flat tax rate.

In the context of a full retirement income stack, assurance vie withdrawals can be timed and sized to use the annual allowance efficiently, topping up income from other sources to the desired level while keeping the taxable component minimal. For British expats, the Luxembourg assurance vie also provides the Triangle of Security asset protection and portability across jurisdictions that French domestic policies do not offer, which is particularly valuable for those who may not remain in France permanently.

The combination of Roth IRA income (tax-free in France) for Americans, or State Pension and assurance vie income for British expats, with careful drawdown from pre-tax pension accounts to fill lower French tax brackets, is the structural basis of an optimized cross-border retirement income plan. The optimal mix is personal to each retiree and cannot be determined without a full view of all income sources and both tax systems simultaneously.

Currency: The Silent Variable That Shapes Every Income Stream

Every British expat drawing a sterling-denominated pension and every American drawing a dollar-denominated Social Security payment is exposed to currency risk, whether they have thought about it explicitly or not. In 2025, the dollar lost approximately 12 percent against the euro. A Social Security payment of USD 2,500 per month was worth approximately EUR 2,375 at the start of 2025. By the end of the year, the same dollar payment was worth closer to EUR 2,075. That is a real income reduction of EUR 3,600 over the course of a year, with no change in the underlying benefit amount.

Sterling has faced its own pressures against the euro, with EUR/GBP rising toward 0.89 to 0.90 through 2026. A fixed UK DB pension of GBP 2,000 per month was worth approximately EUR 2,300 at a rate of 0.87 but falls to EUR 2,200 at 0.91. Over a twenty-year retirement, these fluctuations accumulate into very large differences in real purchasing power.

Currency risk in retirement is not a problem to solve once and forget. It is a structural feature of a cross-border retirement that requires an ongoing, coordinated strategy.

The French Tax Return: Declaring Everything, Taxing Less Than You Fear

French tax residents must declare all worldwide income on their annual déclaration des revenus, including income that is exempt from French tax under a treaty. This surprises many expats who assume that income excluded from French tax does not need to be declared. It does. France uses the declared foreign income to determine the taux effectif (effective rate) method: treaty-exempt income is counted for bracket purposes to set the rate, but the tax is only applied to French-taxable income. The effect is that treaty-exempt income can push you into a higher bracket for the taxable income, even while remaining exempt itself.

This interaction makes the sequencing and mix of income sources material to your actual French tax bill, even for income that France does not directly tax. A retirement plan that looks efficient in isolation may produce a different bracket interaction than expected when all income streams are declared together. Modeling the full French return, including treaty-exempt items, is a standard part of cross-border retirement planning with a specialist adviser.

The Form 3916 Obligation

Every French tax resident must declare all accounts held at foreign financial institutions on Form 3916, filed annually with the French return. This covers US retirement accounts, UK pension platforms, overseas bank accounts, and foreign investment portfolios. It is a disclosure form, not a taxation trigger, but failure to file carries per-account penalties. British expats with both a UK SIPP and a UK bank account and a UK investment ISA must file a Form 3916 for each. Americans with a 401(k) and a brokerage account must do the same. This compliance habit should be built from the first year of French residency, not discovered three years later.

Why Cross-Border Retirement Planning Cannot Be Done Alone

Each income stream described in this guide has its own rules. Each pair of income streams has its own interaction. And the combination of all of them, considered across two tax systems, two or more currencies, a treaty, annual compliance obligations in multiple jurisdictions, and a retirement horizon that could span thirty years, produces a level of complexity that is genuinely beyond what a well-informed individual can reliably optimize without professional support.

This is not a failure of intelligence or effort. It is the nature of the problem. A British or American retiree in France is navigating a system that was designed by multiple governments for their own domestic purposes, with cross-border coordination provided only partially and imperfectly through treaties. The adviser’s role is to hold the whole picture simultaneously and translate it into a clear, actionable income plan that the retiree can actually live from.

Harrison Brook USA works with American expats whose retirement income spans the US and France. Harrison Brook France works with British expats drawing from UK pensions and French assets. Both firms are independent, focus on financial planning and investment advisory rather than tax preparation, and work alongside a qualified tax professional rather than replacing them. The financial planning and investment layer, which is what we provide, is the part that determines how efficiently your retirement income actually flows.

Frequently Asked Questions

I have income from the US, the UK, and France. Do I pay tax three times?

Not if your plan is structured correctly. Tax treaties between France and the US, and between France and the UK, provide frameworks to prevent the same income being taxed twice by allocating taxing rights between the countries. The US savings clause means Americans always owe US tax on worldwide income, but treaty credits prevent double payment. Getting this right requires filing correctly in each relevant country and using the credit mechanisms properly, which is a job for a qualified expat tax professional working alongside your financial adviser.

At what age should I start drawing from my retirement accounts in France?

The answer depends on the specific interaction of all your income sources in each year of retirement. For Americans, drawing from Roth before Traditional accounts in years of lower total income, and managing IRA withdrawals to stay within certain brackets before RMDs begin at age 73, is a common framework. For British expats, the interaction of SIPP drawdown with State Pension income and French income tax brackets drives the sequencing. There is no universal answer; the optimal withdrawal sequence is personal to your income mix and requires specific modeling.

Is assurance vie accessible to both American and British expats in France?

French domestic assurance vie is generally not available to US citizens due to FATCA compliance complications for French insurers. Luxembourg assurance vie is also generally not structured for American clients for the same reasons. British expats in France, by contrast, can typically access both French and Luxembourg assurance vie products, which is one reason the product plays a larger role in British expat retirement planning in France than in American expat planning.

My UK State Pension and French retraite do not cover my expenses. How do I fill the gap?

This is the core retirement income planning question for many British expats in France. The gap is typically filled from a combination of SIPP drawdown, assurance vie withdrawals, and investment portfolio income, in proportions that are determined by their respective tax treatments, your target annual income, and how long you need the portfolio to last. Modeling this sustainably across a thirty-year horizon, accounting for inflation, currency movements, and sequencing of returns risk, is the central task of retirement financial planning with an adviser.

Should I take my SIPP as a lump sum or drawdown?

For most French-resident British expats, drawdown is more tax-efficient than a full lump sum withdrawal, because spreading income over multiple years keeps each year’s taxable income in lower brackets. The 25 percent tax-free lump sum (pension commencement lump sum) available under UK rules is a specific planning consideration: taking it at the right time in retirement, and structuring how the remainder is drawn down, can meaningfully improve the overall tax outcome. This decision should be made with an adviser who knows both your UK pension rules and your French tax position.

Does Harrison Brook do tax returns?

No. We are a financial planning and investment advisory firm. We focus on how your retirement income is structured, invested, and drawn down across both countries, not on the filing of your tax returns. For US expat tax filing, we recommend a qualified US CPA who specialises in expat returns. For French tax filing, a French tax adviser. We coordinate with both as part of providing joined-up financial planning, but the tax compliance filings themselves are theirs to prepare.

Your Retirement Income Spans Two Countries. Your Adviser Should Too. Harrison Brook works with American and British expats in France who needa financial adviser who can see the whole retirement income picture at once,across every income stream, every currency, and both tax systems. Book a free initial consultation today.

Disclaimer: This article is for informational purposes only and does not constitute financial, tax, or legal advice. Tax rules in the United States, United Kingdom, and France change frequently and individual circumstances vary significantly. Treaty provisions are complex and their application depends on specific facts. Harrison Brook USA and Harrison Brook France are financial planning and investment advisory firms and do not provide tax preparation or tax advisory services. Please consult a qualified cross-border financial adviser for personalized financial planning guidance and a qualified tax professional for tax compliance matters in each relevant jurisdiction.