In an update to our article 26 May, we have now received direct confirmation from ENIM that mariners who are resident in France and who are not paying into a mandatory social security scheme will not be considered to be exempt from enrolment into French social security.
This means that voluntary Class 2 NICs paid in the UK will not take away a liability to France. Only membership of a compulsory EU Treaty or Reciprocal Agreement country’s contribution scheme will be enough.
The 1st July deadline for enforcement of the Decret 2017-307 rolls closer: it is imperative that everyone who is affected is properly prepared.
We would encourage all mariners, employers and vessel owners who have concerns to seek professional advice.