Bitesize Guide to Working Across Borders









Bitesize Guide to Working Across Borders

RIFT: Working Across Borders is a special interest group focused on ensuring that, post Brexit, UK citizens living in France understand their rights, obligations and options as cross border workers. (

The European Union (EU) definitions of a cross border worker (, or frontier worker ( are specific and limited when looking at real working patterns. These definitions determine that the workers return to their country of residence on a nightly or weekly basis.

Why does this matter?

Under the Withdrawal Agreement, those EU defined cross border workers will, at the end of the transition, continue to benefit from coordinating social security systems between their country of work and their country of residence.

This means that social security contributions in the country of work will continue to support healthcare costs for the worker and dependants, contribute to pensions, and will allow unemployment benefit to be claimed (if ever required) from the country of residence. These are called exportable benefits and entitlement to them is represented by the S1 document, which in turn enables the application for the carte vitale.

If you are working in the UK and living in France, or considering doing so, discuss your eligibility for the S1 by telephone with HMRC on 0044 191 203 7010

If you are living in France and working in a different EU country, usually the social security institution in your country of work is responsible for issuing the S1.

For more information about social security cover when working across borders:


What about tax?

As a worker in UK but resident in France, due to the bilateral tax agreement, you will continue to pay tax on your earnings in UK and declare global earnings in France each year.

Resident in France, but working in another EU country? The rules on taxation are not covered by an EU community rule and are the results of negotiations between two individual member states. Therefore you may find that tax is payable in the country of work, or of residence, or in both countries.

For more information about double taxation when working across borders:

Frontier workers permit

Article 26 of the Withdrawal Agreement says, The State of work may require Union citizens and United Kingdom nationals who have rights as frontier workers under this Title to apply for a document certifying that they have such rights under this Title. Such Union citizens and United Kingdom nationals shall have the right to be issued with such a document.

We have no further information on this as yet.

Other working patterns

Many of our members’ working patterns do not fit into the neat outlines of the EU definition of a cross border/ frontier worker. As the definition is used for all EU member nations’ workers to assess eligibility to benefit from coordinated social security systems, it is unlikely to change in the ongoing EU/UK discussions.

To explore different ways to continue living legally in France while working self-employed, for a UK employer or as an employer, please see the files section of RIFT Working Across Borders.

Further reading

The Withdrawal Agreement

Julie Hall, May 2020.


Remote working in France


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