Since 1 January 2021, the United Kingdom is no longer a member of the European Union or the European Economic Area. Any UK tax resident selling a property in France is now treated fiscally as a non-EEA non-resident — with an obligation to appoint an accredited tax representative and the application of the full social levies rate. This page explains the practical consequences and the steps to follow.
The Major Post-Brexit Change
Before Brexit, UK residents benefited from EEA member status: they could dispense with an accredited tax representative in most cases, and their capital gain was only subject to the solidarity levy of 7.5% instead of the social levies at 17.2%. Since 2021, both these advantages have disappeared.
In practice: if you sell in 2026 a property bought before 2021, your French tax situation now depends entirely on the rules applicable to non-EEA non-residents — and not on the EEA regime in force at the time of your purchase.
Consequence 1: Accredited Tax Representative Now Mandatory
As soon as the sale price exceeds â¬150,000 or the property has been held for less than thirty years, you must appoint a tax representative accredited by the French tax authority. Without this appointment, the notary cannot finalise the signature.
Consequence 2: Social Levies at 17.2%
The overall capital gains tax rate is now 19% income tax + 17.2% social levies = 36.2%, compared to 19% + 7.5% = 26.5% for EEA residents. The difference, on a capital gain of â¬100,000, represents almost â¬10,000 in additional tax — a compelling argument to optimise everything possible (costs, works, exemptions).
The France-UK Tax Treaty and the British Capital Gains Tax
The tax treaty signed on 19 June 2008 between France and the UK grants France the right to tax capital gains on property located in France. The UK resident may then be subject to Capital Gains Tax (CGT) in the UK on the same capital gain, with a tax credit mechanism to avoid economic double taxation.
UK CGT applies a different rate (10% or 18% depending on income bracket, 18% or 24% for residential property since 2024) with its own calculation rules. Coordination with your HMRC tax advisor is recommended to anticipate the UK tax liability.
Typical Case Studies for UK Residents
Case 1 — 16 years of ownership: Property bought for â¬280,000, sold for â¬480,000 in 2026. Gross gain after flat-rate costs: â¬137,000. Income tax allowance (11 years à 6%): 66%. Social levies allowance (11 years à 1.65%): 18.15%. Income tax: â¬137,000 à 34% à 19% = â¬8,850. Social levies: â¬137,000 à 81.85% à 17.2% = â¬19,287. Total France: â¬28,137.
Case 2 — 8 years of ownership: Property bought for â¬500,000, sold for â¬700,000 in 2026. Gross gain after flat-rate costs: â¬87,500. Income tax allowance (3 years à 6%): 18%. Social levies allowance (3 years à 1.65%): 4.95%. Income tax: â¬87,500 à 82% à 19% = â¬13,633. Social levies: â¬87,500 à 95.05% à 17.2% = â¬14,304. Total France: â¬27,937. UK CGT to be assessed separately.
ACCREDITAX’s Role for UK Residents
Our mission for UK residents has two stages: first, systematic competitive tendering among accredited tax representatives, reducing representation fees by 20 to 40% on average. Then, careful review of the file to apply all possible deductions — actual costs if higher than the flat rate, documented renovation works, possible first-sale exemption after transfer of domicile.
FAQ — UK Residents
I bought my property before Brexit. Am I subject to the new regime?
Yes. The applicable tax regime is the one in force at the date of the sale, not at the date of the purchase. A sale in 2026 by a UK resident is subject to the non-EEA regime, regardless of the date of acquisition.
Have the holding period allowances changed since Brexit?
No. The allowance schedule is identical for all non-residents. Only the social levies rate (17.2% instead of 7.5%) has changed for UK residents since 2021.
Do I also need to declare and pay a capital gains tax in the UK?
Yes, under British CGT. But the tax treaty provides a tax credit to avoid economic double taxation. Check the exact terms with your UK tax advisor.
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