[Originally published in February, last updated on June 24, 2016]
UK citizens have voted in a national referendum on June 23 to officially leave the European Union. The process, generally known as “Brexit”, now engages a long and intricate negotiation between the UK government and the remaining 27 member nations of the EU, plus the European Commission and the European Parliament. The process is likely to take at least two years. During the transition, the UK remains a full member of the EU.
We know you have many questions and there will be many more coming up as the news settles, so following the announcement of the Brexit vote we look at the main meaning and potential consequences of the UK’s vote to leave the European Union, and the effects on British nationals who live or own property in France.
What happens now that the UK voted to leave the EU?
The terms of the exit will be negotiated. There are five models to choose from, the Economist explains.
1. To join the European Economic Area (Norway, Iceland and Liechtenstein)
2. Not join the EEA but sign a number of major and minor bilateral agreements with the EU (Switzerland)
3. Seek to establish a customs union with the EU (Turkey) or at least a comprehensive free-trade agreement
4. Rely on normal World Trade Organisation (WTO) rules for access to the EU market
5. Negotiate a special deal for Britain alone. The European Union has not granted the United Kingdom any special dispensations from its rules in the deal struck in Brussels on February 19, RFI reports.
One element that has been widely speculated about is the potential slump on the British pound. As currency experts Moneycorp write, there is likely to be increasing market volatility for a while after the results are first announced, as the market adjusts to the new positions. Such was the case with the Scottish referendum, when the pound dropped to £1=€1.24 before the vote, before surging to a 2-year high versus the euro, as Scotland voted no. It is reasonable to expect significant market and currency movements immediately after such a result, until markets are confident they understand what lies ahead for the UK economy.
Brexit is not likely to affect the right of a UK national to own property in France, as any other nationality can already enjoy this same right today, including citizens from non EU-countries such as the many Canadian, Australian, American or Chinese owners of French property.
The main question mark is how property inheritance and taxation rules would apply. French real-estate is subject to French forced-heirship provisions, which in practice means that the French legal system will decide who receives the property following the death of the owner. At the moment, according to EU rules, any British national who has property in France can choose either the law of the country of their habitual residence, or the law of their nationality (or choose one of their nationalities if multiple) to govern the devolution of their French estate.
Cross-border solicitor Charlotte MacDonald explains that it will make absolutely no difference in terms of the devolution of your assets whether the UK is in the EU or not, since the UK opted out of the regulation and is therefore already treated as a state outside the EU for succession purposes.
UK residents in France
The rights of British citizens to reside in France would depend on what form of exit is implemented. If the UK opts for option one, to be an EEA member as Iceland, Norway and Lichtenstein are, UK nationals would still be entitled to live and work in the EU, though there would be certain restrictions to some rights and social benefits.