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France–UK corridor

France–UK: settling, investing and selling on both sides of the Channel.

The UK residence regime that replaced “non-dom” status, stamp duty land tax, non-resident landlords, VAT after Brexit and British investors in France.

Checked 28 October 2026Treaty of 19 June 2008
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The short answer

Published under the editorial responsibility of Naym Boutfirass, President of SFISources reviewed on

Since Brexit and the UK reform of April 2025, the France–UK corridor has changed in nature: the concept of domicile has been replaced by a residence-based system, intra-EU VAT no longer applies, and stamp duty weighs heavily on foreign property buyers. The treaty of 19 June 2008 remains the foundation, with a separate treaty for inheritance.

Arriving in the UK. The foreign income and gains (FIG) regime offers, on application, four years of exemption on foreign income and gains for individuals who were not UK-resident in the previous ten tax years. It costs the personal allowance and the annual capital-gains exemption.

Buying and letting. SDLT combines a rate scale, a surcharge for additional dwellings and a surcharge for non-residents. A non-resident landlord normally suffers 20% basic-rate withholding on rent unless approved in advance (form NRL1).

Selling goods. The UK is outside the EU: B2B sales to the UK are no longer intra-EU supplies. Import, incoterms and any delivered-duty-paid arrangement need a customs and VAT review before the first shipment.

Key figures

Each figure points to a source listed at the bottom of the page. Rates change: re-read the source at the date of the transaction.

25%

UK Corporation Tax, main rate (19% up to £50,000)

gov.uk, Corporation Tax rates
20%

UK VAT, standard rate

gov.uk, VAT rates
4 years

FIG regime for new residents

HM Treasury technical note
5% + 2%

SDLT: additional dwelling + non-resident, on top of the scale

Secondary source — to be validated

Key rules

Main France–UK rules
TopicRuleSource
FIG regimeFrom 6 April 2025: four years on application for someone not UK-resident during the previous ten tax years; personal allowance and annual CGT exemption are lost; Overseas Workday Relief kept for three years.HM Treasury technical note
End of remittance basisAbolished from 6 April 2025; transitional measures (12% rate for some remittances in 2025-26 and 2026-27).HM Treasury technical note
Inheritance tax and residence“Long-term resident”: resident in at least 10 of the last 20 tax years; worldwide estate exposed; tail of 3 to 10 years after leaving.Secondary sources — to be validated
SDLT standard scale (from 1 April 2025)0% to £125,000; 2% to £250,000; 5% to £925,000; 10% to £1.5m; 12% above.GoFile (secondary) — to be validated
Additional dwelling / non-resident+5% on each band (since 31 October 2024) and +2% for non-resident buyers.GoFile (secondary) — to be validated
Non-resident landlord schemeTenant (if rent exceeds £100 a week) or agent withholds basic rate (20%) unless NRL1 approval; UK return normally due.LITRG (secondary) — to be validated

The treaty of 19 June 2008

France–UK treaty, main allocation rules
TopicRuleArticle
Dividends15% cap; 0% if the beneficiary is a company subject to corporate tax holding at least 10% of the capital; special rules for some property vehicles.Treaty text
Interest and royaltiesTaxable only in the beneficial owner’s state of residence (0% withholding) except permanent establishment and special relationships.Treaty text
Real propertyIncome and gains taxable where the property is located.Art. 6
ResidencePermanent home, centre of vital interests, habitual abode, nationality, mutual agreement; companies: place of effective management.Art. 4

Which profile are you?

French residentUK propertySDLT at purchaseUK rentNRLS withholdingFrench returntreaty credit
A French resident buying in the UK

Individual moving to the UK

Residence, FIG regime, French exit taxation, inheritance and IHT.

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Buyer or landlord in the UK

SDLT, rent withholding, UK and French filings.

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Company selling to the UK

Post-Brexit VAT, import, incoterms, DDP, permanent establishment.

Scope this case

British investor in France

Rental income, capital gains, wealth tax on property, SCI, tax representative.

Scope this case

A worked example

Illustration only: assumptions are explicit and the figures are rounded.

Cas pratique

A French resident buys a £500,000 second home in England

Les faits

  • Buyer is French tax resident (non-UK resident) and owns a main home in France
  • Residential property bought for £500,000 in England; rates in force since 1 April 2025
  • Assumption: the 5% additional-dwelling and 2% non-resident surcharges apply

La question

How much SDLT?

  1. Standard scale: 2% on £125,001–£250,000 = £2,500; 5% on £250,001–£500,000 = £12,500; total £15,000.
  2. Additional-dwelling surcharge: £500,000 × 5% = £25,000.
  3. Non-resident surcharge: £500,000 × 2% = £10,000.
  4. Total SDLT: £50,000, i.e. 10% of the price.

À retenir. Stamp duty can be over three times the standard bill: price it before making the offer, not at completion.

Rates taken from a secondary source; re-read gov.uk before any offer. First-time buyer relief and Scottish or Welsh rules are not covered.

Frequently asked questions

Does the “non-dom” regime still exist?
No. It was replaced from 6 April 2025 by a residence-based system with a four-year foreign income and gains regime for new arrivals.
Is there still intra-EU VAT between France and the UK?
No. The UK is outside the EU; B2B sales are exports/imports with customs and VAT consequences.
Do you give UK legal advice?
No. SFI analyses the French side and the treaty, and coordinates UK-law points with a locally qualified professional.

Sources

Scope. SFI analyses your situation under French law and tax treaties and coordinates the UK law analysis with a locally qualified professional. SFI is neither a law firm nor an accounting firm; no tax saving is guaranteed; SFI does not claim any office abroad.

Your France–UK situation

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Direct contact
WhatsApp+33 7 82 33 50 27 Phone06 18 40 17 31 E-mailnaym@strat-fiscal.fr
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  3. If an engagement is useful, you receive a written proposal. Nothing starts without your approval.