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Living between UK / France - License Options

I’m UK resident and spend say 80% time in UK today. Over the next five years that will gradually flip to 60/40 in france/uk.

Sounds very much alike @Ibra’s situation… but he’s kinda vanished.

Dan
ain't the Destination, but the Journey
LSZF, Switzerland

AFAIK he lives in the UK and works in the UK.

Clearly, if you move around a lot, this works fine. Maybe @lionel knows the detail but repeated visits to EU Country X cannot possibly accumulate towards the 6 month limit that triggers temporary import. Also there have been various similar scenarios e.g. a French 28 day limit on long term parking of non-F-reg Annex 1 which reportedly could be solved by flying out of France for a day every 28 days.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Also there have been various similar scenarios e.g. a French 28 day limit on long term parking of non-F-reg Annex 1 which reportedly could be solved by flying out of France for a day every 28 days.
And then bad weather happens.
I wouldn’t want to put myself under that kind of pressure by going near that limit – that’s get-there-itis in it’s pure, unadultered form.
EDBW, Germany

The biggest problem is not an aviation one but an EU residency one.
To be in France for more than 90 days out of every 180 you need. To be a French/EU citizen or have French residency. French residency does not give you the right to go and live in Spain or even visit it or any other EU country for more than 90 days out of 180.
Being a French citizen or a French resident (not so sure about this one, it may be just earnings in France) you need to declare world wide income, just as you do if
you are a US citizen. Any earnings in the UK has to also be declared in the UK.
I don’t know if the OP is intending to retire to France but at 60/40 France/UK any pensions will need to be declared in France and tax paid in France unless the OP is on a government employee pension scheme in which case the tax is paid in the UK but still declared in France. Then there is health insurance.
Getting more back on topic to fly an F reg plane at a French club you need to join the club, join the FFA and you need an EASA licence and class 2 medical. It can be any EASA country but you will need to have the ability to speak French added to a French licence (it’s part of the radiocommunication licence)or/ and ability to speak English added to any other EASA licence.
You might be able to get a waiver from the DGAC for a short period to fly an F reg on a UK licence. But not as a resident of France. It would be for the DGAC to decide on an individual basis. You can fly a G reg on a UK licence to and from France and even have hangar space here, but there is the 28 day limit. To keep a G reg permanently here is only possible by ignoring regulation and hoping you won’t be found out (you are unlikely to be found out in most areas of France). But that can also possibly leave you uninsured in certain policy
areas.
So really the OP has to decide where his/her residence is for tax purposes before anything else.
If like many UK pilots, I know , EG those that have a house on one of the air parks around here and fly regularly back and for the UK for work, they have to decide whether or not to declare themselves as residents of the UK which limits the time they can spend here or they can apply for a visa allowing them to visit their second home more often. This could change with the introduction of the new EU entry and exit arrangements. The general rule is if you réside in a country for more than 183 days in a year you become fiscal in that country and must declare for tax in that country and in the case of France you now must be a resident of France or a citizen of an EU country.
The alternative is to simply hold a UK licence and an EASA licence ( in the case of the OP, the simplest would be a French one but it doesn’t have to be). Renting from a club on say a Maltese licence would be up to the club. However, it does depend on the OPs abilities in the French language as a check flight would be required at that club and many instructors at the smaller clubs do not speak a great deal of English and that can make a check flight a little fraught, shall we say.🙂

France

And then bad weather happens.
I wouldn’t want to put myself under that kind of pressure by going near that limit – that’s get-there-itis in it’s pure, unadultered form.

But, nobody is going to be watching you… unless you run a pilot forum or draw attention to your CAA’s infringement persecution policy

You can fly a G reg on a UK licence to and from France and even have hangar space here, but there is the 28 day limit.

I don’t think so. Only Annex 1 foreign regs are limited to 28 days in France. Some countries ban even certified foreign reg long term parking but France is not one of them.

Administrator
Shoreham EGKA, United Kingdom

The reason I wrote about the 28 days is that you have brought it up on several occasions and I know of a guy here who has just sold his certified G reg rather than transferring it to F reg or keeping it here on G reg. All the G regs around here have disappeared in the last year or so. So I was just putting 2 and 2 together and thinking it was like the car situation but I don’t know for sure either way.

France

Grazza wrote:

So I need to build up 100 hours in the UK after which picking up an EASA license is simpler.

You may also fly French aeroplanes under a short-term foreign licence validation as established in art 8(3) of Commission Delegated Regulation (EU) 2020/723. There’s no need to complete any exams, medicals, or flight tests. It will require at least one acclimatisation (training) flight with an EASA FI/CRI. This validation is valid for up to 28 days per calendar year. Apply on DGAC/DSAC form 88i-Formlic, under Validation d’une licence étrangèreValidation à titre privé → “Formulaire de demande de validation à titre privé d’une licence OACI” at https://www.ecologie.gouv.fr/politiques-publiques/titres-aeronautiques-etrangers

Capitaine wrote:

You can also mix and match licence/medical, e.g. I have a French PPL and Maltese class 2.

As a French licence holder, it is France and not Malta that certifies your medical fitness, despite the word Malta appearing on the face of the certificate.

London, United Kingdom

@gallois

you have brought it up on several occasions

“you you you you”

Please consider your posting style. On EuroGA we discuss factors affecting GA i.e. potentially all of us.

An actual reading of the link I posted will reveal that it was started by a French pilot. Almost nobody posts anything on EuroGA that is critical of their own country. But sometimes people do, and being “locals” they are well placed to contribute something useful from their own country!

I know of a guy here who has just sold his certified G reg rather than transferring it to F reg or keeping it here on G reg. All the G regs around here have disappeared in the last year or so.

Most likely this is because they were flying G-regs on French (DGAC) EASA licenses! And post-brexit this stopped working. Why were they G-reg? There’s a good question! Avoiding wing spar inspection was one reason (for a time)

If you know of a French law limiting foreign reg (non Annex 1) long term parking, please post it. France proposed an N-reg ban in 2004 (details here) but abandoned it after, reportedly, Dassault kicked up a lot of stink because many of their jets were put on N-reg (and VP-reg etc).

Administrator
Shoreham EGKA, United Kingdom

@Peter I do not understand your aggression in your post #18. I meant no criticism in my post #16. I have read many of your posts on the subject of how long an aircraft can reside in France since the B word. Nobody seemed to be bothered before that and we had several G reg based here and at the 2 nearby airparks. As it had no effect on me I just took for granted that you knew what you knew the situation. I have admitted that I did not make a difference between annexe 1 and annexe 2 and just accepted what you had written along with snippets of what G reg owners were saying around here. It is a very confused situation and when asked for advice I have always suggested to contact the local DSAC as I do not have more than a general picture and have admitted to that. So please tell me “,why the personal attack”?

France

gallois wrote:

The biggest problem is not an aviation one but an EU residency one.
To be in France for more than 90 days out of every 180 you need. To be a French/EU citizen or have French residency. French residency does not give you the right to go and live in Spain or even visit it or any other EU country for more than 90 days out of 180.
Being a French citizen or a French resident (not so sure about this one, it may be just earnings in France) you need to declare world wide income, just as you do if
you are a US citizen. Any earnings in the UK has to also be declared in the UK.
I don’t know if the OP is intending to retire to France but at 60/40 France/UK any pensions will need to be declared in France and tax paid in France unless the OP is on a government employee pension scheme in which case the tax is paid in the UK but still declared in France. Then there is health insurance.

Hi Gallois, yes all these points are valid, as mentioned in one of my earlier posts, unfortunately the world isn’t very well designed for people splitting time in two places. As always with life there are lot’s of what if’s but my wife an i have agreed when i stop full time work, we will shift to france.

But having lived and worked in four countries (i’m not from UK), I have to live with the fact no matter where i am the tax side of things is messy, as i have various pension/equivalents stuck in various jurisdictions.

gallois wrote:

Getting more back on topic to fly an F reg plane at a French club you need to join the club, join the FFA and you need an EASA licence and class 2 medical. It can be any EASA country but you will need to have the ability to speak French added to a French licence (it’s part of the radiocommunication licence)or/ and ability to speak English added to any other EASA licence.

This is valid, and i think reinforces i need to go ‘UK first’. My confidence with french is probably not there yet that i’d feel confident, although having been here a month straight it’s amazing how much faster your language improves when you are immersed vs doing it in London. I think perhaps i should just spend the money on doing some flights with an instructor while here as well. If nothing else i’ll get some very nice views of the mountains down here. My neighbour is part of the aeroclub, it seems very small and gliding focussed, but i’ll ask.

Thanks!

EGSG, United Kingdom
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