Multi-State employment : self-employment in multiple 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 worker’s State of residence will apply if a substantial part of their work is carried out in their State of residence.

Otherwise, the legislation of the State where the self-employed worker engages in their main occupation will apply.
Substantial work amounts to 25 % of total work carried out. For self-employed workers, this is assessed against their turnover, their working hours, their number of services performed, or their income.
The concept of main occupation is assessed with regard to the worker’s fixed and permanent head office and the ongoing nation or duration of their work.

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 Frenchinsured 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.