France-treaty pensions: reverse credit and new tax cards from 2027

Verohallinto has published pension guidance for the new tax treaty between Finland and FranceVero, covering both directions: people resident in France who receive a pension from Finland, and people resident in Finland who receive pension income from FranceVero. The treaty was signed on 4 April 2023Vero, entered into force on 28 August 2026Finlex and is applied from 1 January 2027VeroVero. The signing date decides whether a pension stays under the old or the new treatyVero.

Those already covered stay covered. If you lived in France and received a Finnish pension on 4 April 2023, it is taxed only in France for as long as you live thereVero, with no Finnish tax from 1 January 2027Vero. If you lived in Finland and received a French pension on that date, it is taxed only in Finland for as long as you live thereVero. This grandfathering covers pensions earned through private-sector work or otherwise based on social-insurance legislationVero, and pensions based on voluntary pension insurance taken out by yourself or your employerVero.

Everyone else falls under the new treaty from 2027Vero. A France resident receiving a Finnish private-sector, social-insurance-based or voluntary-insurance pension pays tax to both Finland and FranceVero, and double taxation is removed exceptionally in the paying state, Finland, through reverse creditVero: report the tax you paid to France in your Finnish taxation and Finland takes it into accountVero. To have the French tax credited already on the pension tax card, estimate the French tax and apply for a new card in OmaVeroVero, answering yes to paying tax abroad and entering the estimate; on paper use form 6207a and the reverse-credit item. With a first application attach a French residence certificate, evidence of the permanent home in France and evidence of giving up the Finnish home. Verohallinto then sends the withholding rate to the pension payer automatically each December–January, but you must check the French tax figure on the pre-completed return, including once the final French amount is known, correcting the return or filing a claim for adjustment. Where other French-taxed income exists, only the Finnish-pension share of the French tax counts, apportioned pro rata. Permanent relocation generally requires no remaining home in Finland, a population-register notification and acceptance by the French authorities as treaty-resident.

Special pensions have their own rules. Public-sector service pensions are taxed in both states with relief in the residence stateVero; a person holding only French citizenship pays tax only to FranceVero. A pension based on motor-liability or equivalent risk insurance is taxed only in FranceVero. Even when permanently resident in France, the insured person's health-care contribution of under 2 per cent of the pensionVero is still paid to FinlandVero and is included in the withholding rateVero. Those moving back to Finland notify Digi- ja väestötietovirasto and check their tax cardVero, since French tax is credited only for the period of French residenceVero.

The mirror image applies in Finland. A Finland resident whose French pension started, or who moved to Finland, on 5 April 2023 or later pays tax to FinlandVero, and from 1 January 2027 France may also tax the pensionVero; relief is then given in France, which again reverses the usual residence-state reliefVero. Public-sector pensions follow nationalityVero: a person holding only Finnish citizenship pays tax only to FinlandVero, while a person without Finnish citizenship is taxed only in France under the exemption methodVero, with the French pension still raising the rate on other Finnish earned incomeVero.

The guidance rests on the new Finland–France tax treaty signed on 4 April 2023 and applied from 1 January 2027 (Valtioneuvoston asetus 34/26).