Multi-State employment : salaried employment in multiple countries (member States - 32 countries)

Brexit with the withdrawal agreement that was signed on January 24, 2020 (effective from January 31, 2020) and during the transition period which runs through December 31, 2020

The Social Security legislation of the State of residence will apply :

  • if the worker performs a substantial part* of their work in their State of residence ;
  • or if the employer’s place of business is outside the EU ;
  • or if the employee has multiple employers ;

The Social Security legislation of the State of the employer’s place of business will apply :

  • if the work carried out in the employee’s country of residence is not substantial.

* Substantial work amounts to 25 % of total work carried out. For salaried employees, this is assessed against their number of working hours and/or against their compensation.

As regards France’s relationship with the United Kingdom from January 1st, 2021, we now know more about the measures that will apply under the withdrawal agreement to French insured individuals who established ties to the United Kingdom prior to December 31, 2020 : on cutoff dates for forms issued as certificates of applicable legislation for posted or multi-State workers.