{"id":6886,"date":"2026-10-23T14:00:02","date_gmt":"2026-10-23T12:00:02","guid":{"rendered":"https:\/\/balmontconseil.com\/blog\/retraite-a-l-etranger-six-pays-compares-pour-un-retraite-francais\/"},"modified":"2026-10-23T14:00:02","modified_gmt":"2026-10-23T12:00:02","slug":"retraite-a-l-etranger-six-pays-compares-pour-un-retraite-francais","status":"publish","type":"post","link":"https:\/\/balmontconseil.com\/en\/blog\/retraite-a-l-etranger-six-pays-compares-pour-un-retraite-francais\/","title":{"rendered":"Retirement abroad: six countries compared for a French retiree"},"content":{"rendered":"
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In summary\u2026<\/h2>\n

A retired Frenchman does not choose a country for its tax rate but for the answer to a single question: Which state will tax each of its pensions?<\/b>. In most of the conventions reviewed, a private-sector pension is taxed only in the country of residence, while a former public-sector employee's pension remains taxable in the state that pays it. Two conventions deviate from this rule on one point: the Hong Kong convention for private pensions from a recognized French fund, and the Italian convention for social security pensions.<\/p>\n

The country therefore chooses itself twice: by the local system it offers, and by what its convention with France leaves to France.<\/p>\n<\/div>\n

\u00abI was told that Portugal, Greece, or Singapore are unbeatable for retirement.\u00bb We hear this from a former executive from Lyon who sold his company and receives a private pension, a state pension, and some rental income. His question isn\u2019t \u00abwhere do you pay the least?\u00bb but \u00abwhere will he pay, on each of these lines, and to whom?\u00bb.<\/p>\n

1. Three pensions, three rules<\/strong><\/h2>\n

Private, public, social security: the convention does not treat them the same.<\/strong><\/h3>\n

The agreements distinguish the pension private<\/b> (paid due to past employment), the pension public<\/b> (paid by a state or a local authority) and, in some texts, the pension of social security<\/b>. The general rule is that private pensions are taxed in the country of residence, and public pensions in the country that pays them. Some treaties are exceptions: the treaty with Italy leaves the taxation of social security pensions to the paying country (Article 18, paragraph 2), with the country of residence granting a tax credit, and the treaty with Luxembourg also taxes these pensions at source. Where does your basic or supplementary pension fall? This question is decided by treaty on a case-by-case basis, not by custom: see French pensions for non-residents<\/a>.<\/p>\n

A local preferential regime never takes precedence over the convention<\/strong><\/h3>\n

The case of Greece illustrates this point. A retiree who transfers their residence there can claim, before March 31st, a flat tax rate of 7% on their foreign-source income for fifteen years (Article 5B of the Greek Tax Code), provided they have not been a Greek resident for five of the six preceding years and come from a country with which Greece has an administrative cooperation agreement. The text specifies that Article 5B does not override tax treaties. If the treaty grants the pension to France, the 7% tax does not apply.<\/p>\n

2. The table, country by country<\/strong><\/h2>\n\n\n\n\n\n\n\n\n\n\n
Country<\/th>\nPension from private employment (agreement)<\/th>\nFrench public pension (agreement)<\/th>\nLocal regime or wealth<\/th>\n<\/tr>\n<\/thead>\n
Spain<\/td>\nTaxable only in Spain (art. 18)<\/td>\nTaxable only in the paying state (Art. 19, para. 2), except for residents who are Spanish nationals but do not hold the nationality of the paying state; in principle, in France.<\/td>\nWealth tax: by default, \u20ac700,000 is exempt, and the tax rate ranges from 0.2 to 3.5 times the annual percentage rate (2025 values), which each autonomous community may modify. Assets not covered by other paragraphs of Article 23 of the Convention are taxable only in the State of residence (para. 5). See our article<\/a><\/td>\n<\/tr>\n
Portugal<\/td>\nTaxable only in the state of residence (Art. 19)<\/td>\nTaxable only in the paying State (Art. 20, para. 2, rewritten by the protocol signed on 25 August 2016), except for residents who also hold the nationality of the paying State without having that of the paying State<\/td>\nLocal tax system: our article<\/a><\/td>\n<\/tr>\n
Italy<\/td>\nTaxable only in the State of residence (Art. 18, para. 1)<\/td>\nTaxable only in the paying state (Art. 19, para. 2), except for residents who are Italian citizens but not citizens of the paying state. Social security pension: taxable in the state that pays it, with a tax credit in Italy (Art. 18, para. 2).<\/td>\nSee our dedicated article<\/a> and the new resident regime<\/a><\/td>\n<\/tr>\n
Greece<\/td>\nTaxable only in the country of residence (1963 Convention, Art. 12; Convention signed on May 11, 2022, Art. 17). The applicable text depends on its date of application; this should be verified before any calculation.<\/td>\nTaxable only in the paying State (1963 Convention, Art. 14; 2022 Convention, Art. 18, para. 2)<\/td>\n7 % flat-rate tax on foreign-source income for 15 years, upon request before March 31; the regime of Article 5B does not preclude the convention<\/td>\n<\/tr>\n
Singapore<\/td>\nTaxable only in Singapore (Art. 17)<\/td>\nTaxable in the paying State (Art. 18, para. 2). The convention does not expressly address social security pensions.<\/td>\nForeign-source income received by a resident individual is exempt (section 13(7A) of the local law), except for partnerships in Singapore; no inheritance tax since February 15, 2008<\/td>\n<\/tr>\n
Hong Kong<\/td>\nIt may also be taxed in France if it comes from a fund recognized or regulated by French law (art. 17, para. 1 and 2)<\/td>\nTaxable only in the paying State (Art. 18, para. 2)<\/td>\nNo inheritance tax since February 11, 2006<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Hong Kong is the notable exception for private-sector pensions: among the countries in the table, it is the only one whose tax treaty also allows France to tax such a pension of French origin when it comes from a fund recognized or regulated by French law. Similarly, for social security pensions, Italy leaves taxation to the state that pays them. Therefore, a territory with low taxation does not necessarily exempt one from French tax. To learn more: Singapore<\/a>, Hong Kong<\/a>.<\/p>\n

For the technician.<\/strong> Spain: Convention of 10 October 1995, Articles 18, 19 and 23; Law 19\/1991 on Wealth Tax (Articles 4, 28 and 30). Italy: Convention of 5 October 1989, Articles 18 and 19. Portugal: Convention of 14 January 1971, Articles 19 and 20, and Protocol of 25 August 2016 (Article 20). Greece: Convention of 21 August 1963 (Articles 12 and 14) or Convention signed in Athens on 11 May 2022 (Articles 17, 18 and 29); Article 5B of the Greek Tax Code (Law 4172\/2013), application to the tax authority (AADE) before 31 March. Singapore: Convention of 15 January 2015, Articles 17 and 18. Hong Kong: Convention of 21 October 2010, Articles 17 and 18. French references: Articles 4 B (tax residence) and 164 B (French-source income of non-residents) of the French General Tax Code (CGI). Health: Regulation (EC) No 883\/2004, Articles 24, 25 and 27.<\/p>\n

3. Case study: two pensions, two states<\/strong><\/h2>\n

Situation.<\/strong> A 63-year-old retiree receives \u20ac30,000 per year in private pension and \u20ac12,000 per year in pension from a former French civil servant, totaling \u20ac42,000. He is considering moving to Spain or Greece. Assumptions: his only income is this combined pension, which remains constant over the period, and the retiree is neither a Spanish nor a Greek citizen. This is an illustrative example, calculated using the rules in effect on October 23, 2026.<\/p>\n

Issue.<\/strong> What is left for France?<\/p>\n

Strategy.<\/strong> Apply the rule of its convention to each line, instead of reasoning about the total.<\/p>\n

Result.<\/strong> Spain: The private pension (\u20ac30,000, or 71.43 % of the total) is taxed only in Spain; the public pension (\u20ac12,000, or 28.57 %) remains taxed by France, the paying state. Greece: The convention assigns the private pension to Greece (Article 12 of the 1963 convention, Article 17 of the 2022 convention), therefore the flat rate of 7 % gives 7 % \u00d7 \u20ac30,000 = \u20ac2,100 per year, or \u20ac31,500 over 15 years, for this line item; the public pension remains taxed by France, the paying state, and is not subject to the flat rate. In both countries, the figure depends on a line-by-line analysis, not a single rate.<\/p>\n

Our position<\/strong><\/h2>\n

Ranking your pensions before choosing your country<\/strong><\/h3>\n

Three steps. List your pensions and determine their type: private, public, or social security. Read the "pensions" section of the agreement for each country you're considering and compare it to the local system: a preferential rate is only valid if the agreement allows the host country the right to impose it. Finally, address your healthcare needs before signing a lease: within the European Union, the European Economic Area, or Switzerland, the S1 form, requested from your pension provider before departure, grants access to healthcare in your country of residence covered by the French system; outside this area, in Singapore or Hong Kong, for example, French health insurance coverage ends. Our work begins here: specifying, in your application, which line item goes where. For countries with detailed agreements: Spain<\/a>, Portugal<\/a>, Italy<\/a>, Greece<\/a>.<\/p>\n

Frequently asked questions<\/strong><\/h2>\n

Is there a country where my French pensions would not be taxed anywhere?<\/strong><\/h3>\n

The convention allocates the right to tax; it does not grant exemptions. A lack of tax liability stems from the local tax system, not the convention, and a public pension left to France remains taxable there.<\/p>\n

Do I still need to declare my pension in France if I retire abroad?<\/strong><\/h3>\n

Yes, for French-source income that remains taxable in France (for example, a public pension or rental income from properties located in France). The pension must also be paid abroad: see the life certificate<\/a>.<\/p>\n

Is a tax package for retirees enough to choose a country?<\/strong><\/h3>\n

No. The flat rate for Greece, for example, is conditional on the length of prior non-residence, the country of origin, and the applicable agreement. It does not replace reading the agreement or other country-specific costs.<\/p>\n

Are you planning your retirement abroad?<\/b><\/p>\n

The first interview is used to classify your pensions, to read the agreement of each country under consideration and to eliminate those that do not apply.<\/p>\n

Are you a notary, chartered accountant, lawyer, or fellow consultant?<\/b> And a client retires outside of France? We intervene in a joint contracting capacity on the reading of the agreements: the client remains yours.<\/p>\n

Book an appointment<\/strong><\/h2>\n

The initial consultation is to establish your exact situation and determine if there is anything that can be done\u2014sometimes there is nothing, and we will say so as well. Thirty minutes, with no obligation.<\/p>\n

Book an exchange with Balmont Conseil<\/strong><\/a><\/p>\n

Alexis Sagnier, financial and real estate investment advisor, insurance broker, AMF certified. ORIAS 13003497. Updated on 23\/10\/2026.<\/p>\n

Official sources consulted<\/strong><\/h2>\n