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Pensions in France and the UK with ExamplesThis is an informal compilation of notes concerning retirement pensions as affected by a partial working life in France at the ILL, and the UK. The information is primarily offered as a guide; we cannot be held responsible for accidental inaccuracies or our own misunderstandings. We urge readers to send us comments and suggestions for improvements or clarification.
We were encouraged by the former ILL director Colin Carlile to publish the notes on the ILL website, to help past ILL employees and to gather greater feedback as an increasing number start to assess their possible pension situations.
April 2008 Recent NEWS
The UK Government has announced pension reforms to take effect from April 2010. The most important for ex-pats is the abolition of a minimum of (about) 11 years contributions to qualify for any UK state pension. A full state pension will correspond to 30 years contributions (at present 40).
Most of this web page was written before the changes in pension laws in France were announced in 2003. The details are still being negotiated. We intend updating these notes and the Guide with newer information as this becomes available. Sections subject to modification due to the new laws are marked **.
RETIREMENT GUIDEBOOK
This guide** to assessment of pensions arising in France and the UK was completed by the Ernst and Young Actuariat, Paris, during the summer of 2003 and is available for past and present staff of the ILL. It contains a number of worked examples and offers authoritative guidance on estimating and obtaining pensions. Copies are available from R. Ghosh and B. Donnelly Introduction to French PensionsPensions comprise two parts: the French State Pension, paid by the Securite Sociale ("Secu"), and complementary pensions. At the ILL both employer and employee contribute to both. The complementary pension schemes are contributory; i.e. the pensions are paid out of current contributions rather than profits from investment of incoming money in established funds. The French State Pension Scheme The Secu pension is managed by the CNAV which has local offices, the CRAM. If one retires in France, this office is finally responsible for calculating the number of trimestres one has contributed within the EU. Present practice suggests that the exact figures are not very predictable. For example, in one's first and final years in France additional trimestres may be attributed if Social Security payments exceed certain thresholds. In addition, conversion of UK weeks to trimestres by the CRAM remains worryingly unpredictable despite our analysis of an increasing number of known cases. Note, too, that overlapping French and UK periods are also eliminated. (This arises, for example on joining the ILL part way through the year, say September. The contribution made to the Secu may lead to the rights for 3 trimestres, but one has worked in the UK already for 3 trimestres, hence there is actually an overlap. Complementary Pension Schemes - IPRIS and IRRAPRI IPRIS and IRRAPRI use the basis that the Secu pension has been paid in their assessment of rights to paying out their part of pensions. Until very recent times when numerous new private pension schemes have become advertised, all French pensions have been paid from one or several of these complementary schemes. It is hence understandable that such standardisation has lead to little debate on optimisation of pensions, and that there is a strong link to the French state pension scheme. Summary of UK Social Security BenefitsFull details of these may be found at the Department for Work and Pensions (formerly DSS) website. In addition to pensions UK contributions give access to a number of additional benefits, which are often means tested, and are only available if one has been contributing in the last two years before retirement. A full working life consists of 49 years, though a full pension is granted after 44 years of contributions. A single person's full pension (2004) is about £80. Until recent years it was mandatory to pay for the basic UK state pension when employed and usually a second component, an earnings related complementary pension. More recently it has been possible to opt out of the second. This change was in recognition that the private schemes were often advantageous, being based on with-profits investment. If one is not in employment, or is employed outside the UK, it is possible to pay "Class 3" contributions which continue to build up the entitlement to a full pension after 44 contributing years. (Note the impending change to 30 years).
A full single person's pension (2006/7) is about £87 per week. Until recent years it was mandatory to pay for the basic UK state pension when employed and usually a second component, an earnings related complementary pension. More recently it has been possible to opt out of the second. This change was in recognition that the private schemes were often advantageous, being based on with-profits investment. Voluntary contributions to the UK state pension If one is not in employment, or is employed outside the UK, it is possible to pay Voluntary contributions which continue to build up the entitlement to a full pension after 44 contributing years. If the total number of years of contributions is less than one quarter of the years required for a full pension (i.e. eleven full years in the EU/EEA) then no pension is payable. Otherwise the pension is paid pro-rata at the age of 65 (for women born before 1950 the retirement age is 60, with a correspondingly shorter period for a full pension). Class 2 contributions Class 3 contributions The cost of maintaining voluntary contributions can be offset against French Income Tax, according to one correspondent, by citing this as provision for additional pensions. Student credits If one continues in full time education after the minimum school leaving age (15 or 16) then one is credited with weeks which qualify for pension rights. This terminates at the month of the eighteenth birthday.
Other UK State Pensions In the early sixties the government recognised that private pensions provided by the employer were not well adapted to the increasing tendency of short term employment, especially in the early stages of careers. In 1961 they introduced the State Graduated Pension Scheme into which employees payed into for two years, after which they could then contract-out. This created the basis for an earnings related additional pension which could be continued on changing employment. It was typical for many companies to have more favourable pension schemes and opting out was a standard choice. This scheme was phased out in 1975, and was replaced by the similar SERPS, the State Earnings Related Pension scheme. While not clearly stated it would appear that this is paid in a similar fashion to the State Pension, and may require a minimum number of State Pension contributions to have been made to receive this additional part. Occupational Pension Schemes Governmental agencies usually have some form of contributory pension scheme to top-up the state pension. Private industry typically uses employers and employees contributions to pay into a pension fund. On leaving the UK such funds are frozen, yielding a pension at 65, or may be sold back at the time and hence cancelled. On changing jobs it is sometimes possible to continue with the same pension organisation (e.g. the Universities' USS system) otherwise it is necessary to deal with each component organisation separately. The age at which the pensions become payable thus depends markedly on the original contracts. Some pensions schemes yield regular monthly payments, others may simply provide a lump sum on retirement which is then used to buy an annuity. Retirement AgeIn the UK the age of retirement to receive the UK state pension is 65 (or 60 for women born before 1950). In France the nominal age for retirement is also 65. It is possible to retire in France, i.e. request the full state pension, liquidation, from the age of 60 if one has worked the 160 trimestres. If one has not fulfilled the 160 trimestres it is still possible to retire between 60 and 65, but the Secu pension is reduced significantly, and so are the IPRIS and IRRAPRI pensions, depending on the shortfall in nominal EU years of work. It is worth noting that French governmental employees, including postal workers, railway workers etc., have pensions directly paid by the government and are not in the schemes described above, and the retirement age is often 55 and sometimes lower. We can compare ourselves with others in the CNAV system where the retirement age is spread between 60 and 65. (Follow linked frames etudes...statistiques...attributions) Early retirementAfter reaching 60 the employee cannot be stopped from retiring. The employer can no longer insist that the employee takes up retirement even though he has worked for 160 trimestres. The French Government supports three mechanisms for early retirement: preretraite-licenciement (ASFNE) **preretraite progressive ARPE Retirement Lump Sum PaymentsThe Convention d'Entreprise describes the calculation of the termination payments on retirement. The sum corresponds to a an additional single total monthly salary after 5 years activity at the ILL, two after ten years service.. etc., if the person decides voluntarily to retire after the age of 60. This sum is considered to be a part of the salary, and is consequently fully taxable. **Changes in the law since 2003 has required that the ILL change its policy on insisting staff retire when 160 Secu quarters have been attained. One consequence is the reduction in the termination bonus if the employee continues to work having attained his 160 trimestres. Estimating final pensionsTo give staff an idea of how much cash in hand they might have per month on retirement we have tried to estimate the contributions from the French and UK pension systems. Details of the calculation are somewhat messy in the case of the Secu. The current CNAV website has interactive tools forshowingnthe known EU contributions and pension projections. IPRIS and IRRAPRI pensions are based on having earned points of a defined value in FF. If the employee has not completed 160 trimestres working in the EU, the IPRIS and IRRAPRI pensions are docked by about 4% per missing year. If the employee has brought up 3 or more children the state pension is increased by 10%. For IPRIS and IRRAPRI an increase is already incorporated in the points attributed. Payment of State pensions
For the UK the address is: The local CRAM office: General experience has shown the need to correct information received from Newcastle, and this can sometimes be a protracted operation. On attaining 65 the UK and French agencies, for example, will re-assess the final pension to be paid. Having returned to the UK the DWP will be responsible for assessing the final sum of the pensions. If one lives outside the EU then the UK pension, once established, is not updated with inflation or other increases. The Secu pension is based on 150 trimestres maximum contributions. In the case where 150 contributions have not been achieved by the age of 65, the person continues to work, and the pension is not liquidated immediately, then the net contributions are automatically augmented 2.5% per additional trimestre after the 65th birthday (with a maximum of 150 total). Payment of Complementary Pensions CICAS, Service des residents hors de France, If retirement takes place before the age of 65 then it is necessary to show that the Secu is providing the basic pension. Income tax All pensions are liable to be taxed, and 3.8% or so of IPRIS and IRRAPRI is likely to be removed automatically at source to pay for French CSG and CRDS taxes etc., even when the pension is paid to a person in the UK. This should be countered since the UK is then responsible for health care. CONTACTS for French PensionsState Pension To facilitate the work of the CRAM office you should provide your French Sociale Securite number and a list of French employers, their addresses, and your periods of employment. The CNAV now offers a password-protected internet service to check their data on you. The site is: https://www.retraite.cnav.fr Click on ENTREE You will need to know your 15 digit French Social Securite number. Those with the older 13 digit numbers will have to write to the CRAM office at Lyon. CRAM RHONE-ALPE IPRIS IPRIS IRRAPRI IRRAPRI - Services Administratifs In both cases you should include a list of French employers, their addresses, your periods of employment and your French Social Securite number. Standard documents on applying by mail to the CRAM offices for their judgement on one's working life indicate applying for this six months before the proposed date of retirement; recently the responses have been fairly prompt. Delays may add to the general unknowns for UK staff trying to determine their rights according to the French pension system. ExamplesA number of staff have offered information on their particular circumstances, and we have tried to estimate the various components of the pensions they might receive. We have considered two classes: A common feature is the inevitable period of delay before receiving the first payments from UK pension schemes at 65. When the UK pension becomes payable this should be notified to the French CNAV/CRAM. The French pension is then re-evaluated, and any increase rusulting will be paid from then. A. Examples of fully paid-up workers at/over 60
The examples shown below has been approximately updated to 2007 levels. They serve principally to show the major components of the final pensions.
Example A1 At age 60, 27 years French service, 160+ EU trimestres contributions. receive per month Having maintained voluntary payments to the UK system for 29 years A1 will have contributions needed for a UK state pension. This will yield a partial UK state pension at 65, about £340 pounds per month
Example A2 At age 63, 32 years French service, 160 EU trimestres contributions receive per month With 13 years contributions to the UK pension system, at 65 this will yield about £157 per month B. Examples of incomplete contributions at 60Example B1 At age 60, 25 years service at ILL, 140 EU trimestres contributions. receive per month On reaching 65 additional pensions payable from within the UK: Having maintained voluntary payments to the UK system B1 will have enough contributions needed for a full UK state pension. This will yield a full UK pension, about £336 pounds per month UK company pension (private pension deferred) 6 years contributions
£125 per month ----------------------------
Example B2 At age 60, 31 years service at ILL, 140 EU trimestres contributions. receive per month With only 4 years contributions to the UK state pension scheme this will not result (2007) in any pension benefits from the UK at all. If seven Class 2 contributions were made to bring this up to eleven years (costing about £110 per year) this would yield an additional monthly pension of £96 at 65. Under the new proposals from 2010 this minumum level is abolished but any back years acquired (subject to limits) will, in general,offer a good return for most people, especially being pro rata of thirty years maximum. This last example is typical not only of UK scientists but other non-French Nationals who have made the ILL their principal career, and who now discover that they must continue to work to 65 to minimise the penalties built-in to the present French pension schemes. Frequently asked questionsThis section contains questions primarily concerning problems which may arise on return to the UK, to which we are only now trying to find answers... Will I be entitled to free UK-NHS Health care? Will I have to maintain a French bank account after return to the UK? Can I get equivalent advantages, i.e. UK private health care, as offered to ILL retirees paying and staying in the ILL-Mutuelle? What unemployment benefits follow on in the UK from unemployment insurance in France? Do I have to pay DSS insurance contributions on returning to the UK at 60? Can I avoid the automatic deductions made to the French pensions for the French Health service when resident in the UK? If I take early retirement under an FNE plan, am I free to return directly to the UK? If I take up retirement under the FNE will the ILL help me in future dealings with the French institutions?
If I return to the UK at 60 and take up employment, can this increase my EU years for the French Pension? Do the French and German scientists face the same problems of attaining their 160 EU trimestres? Is it possible to buy extra years in the French Secu system?
Last modified 10th August 2004, R.E.Ghosh Other useful references A very good general reference book on rights in France is: Rules on the calculation of pensions for EU workers can be found in: See booklet: NP46 A guide to Retirement Pensions (April 2005), Department of Work and Pensions In 1988 the Service du Personnel produced a comprehensive (and colourful) document on pensions: LE DEPART A LA RETRAITE DES AGENTS ILL which was summarised later in an English version by David Gray (1989). French Web-sites French Web-sites Appendix I - Table of Plafond du Securite Sociale - Tranche AThe table below shows the PSS since 1974 with the ratio of the value of currency in that year to that in 2007. The last column is the effective Tranche A in current Euros.
Appendix II - Estimating the French state pensionThis is dependent on the average salary in current francs of the best N years of work. If the salary exceeds the tranche A then this is taken as representing the salary that year. For this reason the tranche A in current FF is given in table I. The number of years N over which the average is made depends on age: Born Number of years If one has been in France for less than the time proposed then the average of the salary during the actual period is used. Two calculations are performed, firstly in the hypothetical case that all contributions during the working life were made to (1)the French system, (2)based on EU: this requires calculating La pension globale theorique , then a calculation on the fraction the French state system should pay on a pro-rata basis, la pension proratisee Using the average salary, S, the rate, R% calculated based on age etc. (as per David Gray below) varying between 25 and 50%, the pension P is as follows for T trimestres:
P = S x R x T/150 (1) French system only Here the rate R is the minimum, 25% because so few years have been contributed. T is the number of trimestres worked in France. (2) EU a) La pension globale theorique The rate is R = 50% for a full period of work. All EU trimestres are counted for T. b)la pension proratisee This is the fraction of P2a obtained by multiplying P2a by the fraction of the French trimestres/Total trimestres The sum which is paid is the larger of P1 and P2b. Example - from example B1 above Pension under the French system only P1 = 167153 x 25/100 x 108/150 = 30087 FF Pension as EU (2a) La pension globale theorique P2a = 167153 x 50/100 x 150/150 = 83576 FF (2b)la pension proratisee P2b = 83576 x 108/150 = 60175 FF The pension based on the EU fractional calculation, P2b, is the larger, and this is what is paid. ------------------------------------------------------------- Rate R% at which pension is paid... Anyone retiring before 65 with less than 160 quarters receives a pension at a rate R diminished by calculating: either a) number of quarters between retirement and 65 The smaller of a) or b) is then multiplied by 1.25%, say W%, and the annual pension above is calculated with R=50% replaced by (50-W)%. If this final figure is less than 25% the value of 25% is used. |