Hello

My husband has his own Accounting business in the UK and we are planning to move to France where I will work for him doing bookkeeping work that he will bring out to me or I will do online and he will work 3-4 days in the UK and then spend the rest of the time in France. Is there anyone out there who can advise on this? I would like to get into the French system so that the family are covered in the French national health system.
=============
The website of the British Embassy and British consolate has a "living in France" section with articles specifically for UK residents in France.

Some other info:

First you need to look at each country’s domestic rules. If you clearly fit one and not the other then your tax residence position will be clear. In both the UK and France a ‘split-year’ approach is generally taken so that on a move you might be treated as resident in each country for different parts of the tax year.

The tax year in France is the calendar year, whereas the UK tax year is 6th April to the following 5th April.

Tie-breaker
If there is any doubt, though, and you simultaneously fit the rules of both countries for any period, it is necessary to look at the ‘tie-breaker’ rules in the Double Tax Treaty.

Once you become a tax resident in France you are liable to pay tax on your worldwide income and gains - and wealth. It is therefore important to know what the residency rules are and whether you are caught by them.

There are three main French domestic rules:
?If your main home (foyer fiscal) is in France, you will be deemed to be resident there, regardless of the number of days you spend in France (if you arrive in France with the intention to reside there permanently or indefinitely you become a tax resident the day after your arrival).

?If your séjour lieu principal (principal place of abode) is France, you are resident in France. This is more difficult to define, but is taken to mean spending 183 days or more of the French tax year in France. These days do not have to be consecutive, and usually include days of arrival and departure.

?If you spend more days in France than any other country, even if this amounts to less than 182 days.

In addition, if you are employed or self-employed in France, you are deemed French resident unless you can show that such activity is incidental to your work elsewhere. Finally, if France is the place of your principal investments, or where assets are administered, or from where a larger part of your income is drawn, you could also be deemed to be French resident under domestic rules.

Domestic rules
You therefore don’t have a choice about being French tax resident - if you meet their domestic rules for residence, you are liable for tax in France.

At the same time, you could also meet the UK domestic residence requirements. This would happen, for instance, if you have been physically present in the UK for at least 183 days in a UK tax year, or if you are present in the UK for an average of 91 days or more per annum, measured over a period of four tax years.

You cannot, however, actually be a tax resident in both the UK and France at the same time according to the Double Tax Treaty between the countries.

Tests
And where you fall resident in both countries under domestic rules, the Treaty ‘tie-breaker’ clause will be applied to decide in which country you are resident for tax purposes. Under this clause, four tests are applied in order. If your residence position can be determined under one test, the remaining tests are ignored. If test one is indeterminate, you move on to the next test, and so on.

?The first test is where you have a permanent home available to you. This can be a rented property, or simply a room specifically set aside for you e.g. with family, not just property that you own.

?Where you have permanent homes available in both countries, you will be resident where your ‘centre of vital interests’ is located, i.e. the country with which your personal, social, economic and professional relations are the closest.

?If this test is indeterminate, you are resident in the country in which you have an habitual abode, which is generally a time based test. If you are spending roughly equal amounts of time in both countries, you are deemed to be resident in the country of which you are a national, and thus UK nationals will at this point be regarded as UK residents.

It is dangerous to rely on the Treaty as it doesn’t always give the expected result, and circumstances can change mid-year that will affect the Treaty position.

Spouses can have different tax residences, but specialist advice is required on this, as there are many points to consider, not least the Treaty and whether or not they are living together or separated.

Rules
It may seem straightforward enough to determine whether or not you are a French resident by complying with the rules. However, if it is uncertain and the double tax treaty has to be used, then you need to convince the UK authorities that you really have left for good, and this is generally best done by centring your life in France and integrating into life there.

If you want to live in France, it may be better to sell all UK property and not to be tempted to maintain a base, however small, for visits, at least for some years after leaving the UK.

Note that French tax residence is different from the French residence permit (carte de séjours), which is no longer required by UK nationals in France but used by some Britons as an identity card, although the French tax authorities are informed when you apply for one (as it’s no longer required for UK nationals, it may be hard to acquire one).

If you are looking to move to France, or even spend half of your time in France or the UK, you need to understand how these rules apply to you in your circumstances, so that you know where and on what you are going to be liable to tax, and can plan accordingly.
=============