3. Protection Universelle Maladie (PUMA)
3.2. How Much do You Pay?
The PUMA charge is called the Cotisation Subsidiaire Maladie (CSM) .
The charge has been the subject of legal controversy, which we have covered in several health articles:
As we stated above, the formula was changed significantly for 2019 onwards, substantially reducing the number of households liable, but it remains a complex formula, leaving many households exempt, granting them free affiliation. We question whether such arrangements are sustainable.
3.2.1. Who is Liable?
One of the most notable characteristics of the charge is that it is applied on an individual basis, not per household, contrary to many other taxes and charges.
Nevertheless, exemptions apply to the whole household where one of them meets the conditions for exemption.
To be liable for the charge three conditions apply:
That you have no professional activity (business or salaried), or that you have a professional activity, but your income from this activity is no greater than €8,105 pa (2019);
That in the second case you also have capital income (revenus de patrimoine) above the exemption threshold;
That you are not in receipt of a pension or unemployment benefit.
In short, the charge is aimed at those who live on their capital income, but who are not of pensionable age.
In relation to pension income, the regulations make no distinction between State retired pensions and early retirement pensions/annuities. They merely reiterate the clause set out in Article L380-2 of the Code de la sécurité sociale, which states individuals are only liable if:
'Elles n'ont perçu ni pension de retraite, ni rente, ni aucun montant d'allocation de chômage au cours de l'année considérée. Il en est de même, lorsqu'elles sont mariées ou liées à un partenaire par un pacte civil de solidarité, pour l'autre membre du couple.'
This clause means that a couple would be exempt if only one of them was in receipt of a pension.
The official guidance on the issue also states that those in receipt of an invalidity pension would also be exempt, as would their partner.
The position of early retirees on a pension remains open to some interpretation, but it seems that the law is being interpreted widely and that anyone with a pension is being exempted from the charge.
Whether that remains the case is questionable, as such pensions in France are normally referred to as a pension de préretraite, a term that is not used in the legislation.
More specifically, the law states exempt households are:
Those who obtain health cover in France via an S1 certificate of exemption, who are insured for health from their home country. This mainly affects EEA nationals on a State retirement pension, but it also includes anyone else who holds a S1 certificate;
Economically inactive individuals with capital income less than a minimum threshold, which in 2019 is circa €20,262 pa;
Business owners and salaried employees with a professional income greater than €8,105 a year, as they pay their usual social security contributions;
Households in receipt of a retirement pension, annuity, widow's pension or disability pension.
The formula means that only those with a professional activity earning below €8,105 pa and capital income greater than circa €20,262 would be liable for the charge in 2019 (payable 2020).
For those with professional income the charge rate reduces progressively with an increase in professional income. In addition, the charge is only applied on capital income above €20,262.
In the case of a married couple or those in a civil partnership, the charge will not apply to either of them where one of them has income from a professional activity above the threshold.
This same rule applies in relation to those couples where at least one of them is in receipt of a pension, when they are both them exempt from the charge.
An upper limit to the capital income that gives rise to the charge is also applies, equivalent to €324,192 (2019). So income over this amount will be exempt from the charge.
The position of those who are covered for health through a private health insurance policy is not stated in the regulations, but many expatriates with such policies have received a demand for payment of the health charge. Once again, the issue needs some legal clarity. There are a number of cases pending in the courts. URSSAF state that those with a private health policy are not exempt from the charge.
3.2.2. Eligible Income
For those with no professional activity, the only income that is assessed is income from capital sources, called 'revenus de patrimoine'. That is to say, investment income, rental income and capital gains.
In addition, if your income from such sources is below a minimum threshold you are also exempt from the charge.
For 2019, if the total net sum of your revenus de patrimoine is no greater than €20,262, you will be exempt.
Only those with a low income-earning professional activity (as above) would have this income taken into consideration in the calculation on a progressive basis.
A married couple or those in a civil partnership each benefit from the above exemption threshold, meaning (broadly speaking) a couple would be exempt if their revenue de patrimoine was no greater circa €40,000.
For the purposes of determining the amount payable the authorities can also take into consideration your lifestyle (train de vie), an assessment that will particularly affect those households living on their capital resources. Details of this process have yet to be published.
In your first year in France, without any previous tax returns having been made, the authorities will assess your contribution level on the basis of your tax return and income in your previous country of residence. If your income has reduced significantly since this time (often the case) then you need to make clear this is the case and provide appropriate and clear evidence. The charge is applied on a pro-rata basis for those not in PUMA for a full year.
The insurance contribution rate is 6.5% of net eligible income.
With the abolition of 'dependant' status (ayants droits) under PUMA, those liable for the CSM will be assessed on the basis of their own eligible income, plus half of the joint revenus de patrimoine they earn with their spouse/civil partner.
As the regulations state: 'La cotisation subsidiaire est individuelle : elle est due par chaque assuré à titre personnel sur ses revenus du capital.'
3.2.4 Payment of the Charge
The charge is levied in November each year, payable in arrears. So the payment for 2019 is due in November 2020.
It is payable either in one single payment or in three equal payments over 90 days for each payment, but only on request. If payment is not made within 30 days of the demand, there is a 5% penalty plus 0.4% interest for each month of non-payment.
3.2.5. Challenging the Assessment
If you wish to contest the imposition then you need to write to URSSAF with your documentary evidence.
If they are unwilling to accept your challenge you are entitled to appeal to the Commission de Recours Amiable (CRA) in the agency, which you need to do so within two months of receipt of the bill, and ultimately appeal to a local court, the Tribunal des Affaires de Sécurité Sociale (TASS).
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