French tax (if any) on earnings within UK pension pots, pre-retirement

Sarah Rama
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Reading through all of the useful advice in the site - thank you again! However much of the advice on UK pensions is geared towards pensions in payment and how that money is treated when received by someone tax-resident in France.  My question is on the treatment of UK pensions accounts before first access.

Husband and I are fiftysomethings who have spent most of our career in the UK and have built up balances in various UK pension accounts. Moving to be tax resident in France from Jan 1 ‘25.

SIPP (personal pension, tax advantaged in UK) for both of us, a pension scheme established in and recognised for tax purposes in UK
Current UK workplace defined-contribution pension, a pension scheme established in and recognised for tax purposes in UK
Former UK workplace defined-contribution pension, in UK tax terms an International Pension Scheme, a pension scheme established in and recognised for tax purposes in UK

All of these pensions are set up as a ringfenced account with a pool of assets, which are UK tax-protected while inside the pension account and only are taxed for the UK when being taken out of the ringfenced pension account.  Within the account are mutual funds, individual stocks earning dividends and capital gains when sold, individual bonds with interest coupons, all of which are untaxed by UK while in the pension account.

We are aware that UK ISAs are treated by French tax authorities more-or-less as just another brokerage account where interest/divis are taxed as they arrive, and any gain or loss on buy/sell taxed as you sell each security or fund.

So the question: are these UK pension funds treated for French tax purposes:

[a] like an ISA or brokerage account, pay French as the money arrives in account, or

while within the UK pension account there is no French tax on the dividends/cap gains/interest earned, and the French tax is only assessed when money is taken out of the pension account?

Sarah

4 replies so far...
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