CASH BUY, STERLING REMORTGAGE OR FRENCH FRANC MORTGAGE ?
Financial considerations
Amount of cash contribution available
French mortgage
With the maximum French mortgage advance being less than the full cost of
the purchase, a cash contribution will be needed to cover the shortfall on the
purchase price, notaire's fees and associated costs with setting up the mortgage
and your deposit.
UK mortgage
If the valuation of your main residence, and your financial status allows,
100% of the overall purchase price (and renovation costs, where applicable),
can be raised in the UK, making the French project possible even if cash resources
are limited or unavailable.
Interest rates present and future
French mortgage
With the ability to opt for a fixed interest rate for the duration of the
loan term, either at outset or at a later date, the French mortgage offers greater
interest rate stability. With the interest rate fixed the Euro payment
due will never rise. Several variable rate schemes limit the extent
that the interest rate can fluctuate. Even with a variable interest rate, interest
rate change can be limited to annual reviews only and offer additional limits
in movement via the cap and collar or capped schemes.
UK mortgage
To remain competitive, fixed rate mortgages are usually restricted for a
short period of between 2 and 5 years. Similarly, cap and collar interest rates
schemes are usually short term. Although the option may exist to take up any further fixed or capped rate at the expiry of the initial scheme, the UK route does offer less interest rate stability than the French route.
Cost to arrange/redeem the loan
Arrangement fees
Whilst costs to arrange a French mortgage do not differ greatly in proportion
to the loan amount no matter whether the mortgage represents 85% or 60% of the
purchase price, nor whether the interest rate is fixed or variable, the cost
to raise funds in the UK can vary significantly.
If there is no indemnity premium to pay, or a cashback incentive is involved,
UK remortgage costs are likely to be lower than for a French raised loan. Generally, however
the higher the percentage advance of the UK property valuation, the greater
will be the UK mortgage arrangement fees involved.
Should you be considering raising fund finance in the UK, please contact our
office for a quotation and comparison of estimated arrangement fees with those
of a French mortgage.
Redemption fees
If the French property is sold before the end of the French mortgage term,
a small fee will be incured via the notaire to discharge the mortgage deed.
Equally an early redemption penalty may apply especially if the French mortgage
enjoys a fixed interest rate.
In the UK most redemption penalties, if any, apply during the period of any
fixed rate, of for a set term in the case of cashback, loyalty bonus and discount
rate mortgages.
Foreign currency exchange rate movements
Since the market prices of French property in general will be represented in
Euros, the sale value of your French property at any one time will be
determined in Euros. With your cash savings and income likely to be
in sterling, the problems of foreign currency risk become apparent irrespectiove of whether or where a mortgage is raised :
If the value of the Euro falls in comparison to sterling the value of
the French property when expressed in sterling will also fall, and vice-versa
when the Euro appreciates against sterling.
The effect of foreign currency movement on the cost of borrowing and the value
of any cash contribution is affected in 2 basic ways :
Current account
If the mortgage is in Euros, the most noticeable immediate effect of foreign
currency exchange rate movements will be in the monthly transfer of sterling
abroad to pay the mortgage. If the value of the Euro falls, sterling
payments fall and vice-versa. Changes in the sterling monthly payment would
also arise if interest rates changed. Fluctuations in the exchange rate affecting
the sterling costs of a Euro mortgage can therefore be linkened to an
increase or decrease in interest rates. By ensuring the French mortgage interest
rate is fixed, the currency risk associated with the French mortgage can then
be compared to the interest rate risk of a variable rate or short term fixed
rate UK mortgage. A long term appreciation in the Euro will have the
same effect as a long term increase in the charge rate of interest as far as
monthly payments are concerned. Please contact our office for an example illustration
of this comparison.
Capital account
Similarly, an alteration in the exchange rate will affect the sterling value
of the French property, although this effect will only be felt if and when the
property is sold. By having the debt (the mortgage) in the same currency in
which the asset (the property), is represented (Euro) exposure to currency
losses on sale is reduced. If a French property purchased for cash or by way
of a sterling mortgage had to be sold and in the meantime the Euro had depreciated,
the sale would generate a loss against the original amount invested, even if
the Euro value of the property remained unaltered.
With a Euro loan, appreciation in the Euro would see an appreciation
both of the value of the house and the outstanding mortgage when expressed in
sterling. Subsequent sale of the house for the same Euro price would
still realise profit however against the cash contribution made at the time
of purchase.
Tax
Income tax
Letting income generated from a French property is liable both to French and
UK Income Tax. Whilst French loan interest can be offset against income
both for French and UK tax purposes, it is less easy to do so for interest incurred on a loan raised in the UK. If you intend to let the property, the French
mortgage therefore offers a distinct advantage over the UK based loan.
Inheritance tax
Property located in France is subject to French Inheritance Tax, with its net
value being the amount against which the tax is calculated. The
existence of a French mortgage secured against the property will subsequently
reduce any French Inheritance Tax bill. In the case of a UK based loan, the
property against which the mortgage is secured is located in the UK and therefore
is not taken into account for French Tax purposes. As a result there is a risk
of a higher French Inheritance tax bill with a UK based based mortgage, during
the mortgage term.
Liquidity of personal assets
Whilst it is comparatively easy to raise capital for almost any purpose against
property already owned in the UK, such capital raising secured against French
property is much more difficult - not generally being available. To recover personal
capital, the French property would therefore need to be sold. This of course
will take time, may realise a loss due to currency fluctuations, whilst the
need for speedy disposal may also create a loss. A sale is also irrevocable - somewhat
drastic if the need for cash is only short term.
A French mortgage at the date of purchase or for renovation would reduce the
cash contribution needed from the UK, and leaving more readily realisable wealth located at home.
Life assurance
In almost all cases, life assurance is compulsory with a French mortgage, thereby
adding to the cost of monthly payments. Most repayment mortgages and some interest
only mortgages in the UK do not require life assurance as additional security, but this may be a personal necessity in any event.
When life assurance is needed, the French block policy will generally be cheaper
and more comprehensive, (also providing disability cover), than any basic UK counterpart.
Conclusion
The above areas are some of the considerations we recommend you should make
prior to deciding upon your method of fund raising. In many cases our report
to you will also include specific factors not raised here.
The degree of importance of each consideration will vary according to:
- your intended use of the property (main or holiday residence to generate income).
- Your asset base and financial circumstances in the UK.
- The availability of a cash contribution.
- Your age and family status.
- The relationship and number of prospective french property owners.
- The loan term and whether you intend to redeem the loan early.
- Future intentions in the UK. preferred.
Overall, whilst both a French and UK loan have similar benefits against UK tax,
a French loan is more useful in combatting French taxation.
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