Brexit: what are the implications for expatriates?

300 000 French live in the Uk and 171 000 in the Uk are settled in France. What will happen to their freedom to work? Their social protection will it be maintained? For the moment, nothing is clear.

Since the vote in favour of a "Brexit", the scenarios on the fate of the Great Britain to develop. More than 300,000 French people live in the uk when 171 000 Britons have chosen to live in France. Will they have to renounce their rights and to request the granting of visas?

For many experts, the "worst" case scenario, one in which the people should give up their social security and apply for work permits - seems unlikely because it would have economic consequences too important.

According to these experts, the community rules will be maintained until new bilateral agreements, or the reactivation of the old convention franco-british in 1956, or even the accession of the United Kingdom to the european economic Area (EEA, which in addition to the members of the EU includes Iceland, Liechtenstein and Norway), an assumption that would guarantee a status quo.

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These discussions could take years. And no one can say whether the new arrangements will maintain the same level of social protection. Overview of the possible pathways.

consequences in the event of economic dismissal?

According to Deborah David, lawyer specialist in labour law, employment contracts should not be affected, because they have already been adapted to the "conditions in the field of labour law" of each country (ex: holidays, minimum wage, paid holidays...).

On the other hand, if the EU decided to adopt a firm position and imposed visa and work permit to uk workers, the Uk could do the same.

The Brexit could also have social consequences in case of economic dismissal. As soon as the actual british will not be accounted for, groups will pass under the threshold of 1,000 employees in Europe, which gives the right to reclassifications, highlights the law firm Pinsent Masons.

rights to unemployment reviewed?

The european rules currently allow any unemployed person moving into another State of the Union to continue to collect her allowance for three months. They also guarantee to a French reworks in France, just after having been fired in the United Kingdom, to enjoy the same rights as if he had contributed in France.

Without the agreement or accession of the United Kingdom, the EEA, the compensation rules that will apply to such a person after his return in France will be those reserved to the unemployed who have worked in a non-european country, affiliated as optional, with a condition: they have worked at least 18 months during the last 24 months.

The French seconded by their employer are not affected. The affiliation to the French regime as unemployment is for them compulsory, they are - and will remain - covered if they lose their job.

uncertainty over future health coverage

The european expatriates are subject to the regime of the country where they reside and contribute. In contrast, a posted worker, such as a French trader working in London for a French bank depends, and will continue to rely on the French social security, with the beyond 24 months, the need of"a special authorisation", specifies the Centre of european connections and international social security (Cleiss).

For retirees, for example, a British retired in the Dordogne, the EU guarantees of health care in France, support in the United Kingdom to repay the France.

That will include the future health coverage? Everything will depend on the chosen scenario, and in the case of a bilateral agreement, no one knows if it will cover all risks, such as today.

What about retirement ?

Currently, a Frenchman who has contributed for several years in the United Kingdom benefits from all its quarters, each plan paying its share of pension.

With the Brexit, the maintenance of the principle of the aggregation of the quarters will depend on the "future agreements", says the firm Novelvy. A French expat who has worked in the Uk and in another State could in effect lose the quarters together in the third countries if the accumulation of bilateral agreements is not allowed, " warns the firm. On the other hand, "nothing would change" if London was joining the EEA.

"The country primarily competent to pay family benefits is one in which the activity is carried out professionally," recalls the Cleiss. This warranty, again, will depend on the scenarios.

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