Lucie Beunel and Elodie Barron have many similarities: they are sisters, they were brought up in rural France, they married in their thirties, and they both have three children. But while Lucie gets €683 (£560) a month worth of help from the state for her children, Elodie gets nothing.

The reason? Barron is raising her family in Britain, which has one of the least child-friendly tax systems in the developed world.

Not only does she now get far less support than her sister, but she even had to pay back £2,000 of the child benefit that she used to get for her three children, Lewis, 17, and 14-year-old twins, Ella and Olivia.

Barron, 49, works in communications and lives in Fareham, Hampshire, with her husband, Lee, 50, who works in IT. The couple hadn’t realised that the state benefit, which used to be universal, had become means-tested in 2013, five years after Lewis was born.

From that date any household where a parent earned more than £50,000 a year started to lose entitlement to child benefit on a sliding scale — once your salary reached £60,000 you were entitled to nothing. (The thresholds are now £60,000 and £80,000.) Anyone getting benefit they were not entitled to has to pay it back through a self-assessment tax return.

The Barrons have since opted out of getting child benefit altogether. They did get some free childcare when their children were in nursery, but it did not cover all their costs. At one point, when all three children needed before and after-school care, they were paying £1,500 a month. Now they get no state support at all.

Family portrait of Lucie Beunel, Antoine Bonamy, and their three children.

Lucie Beunel and her husband, Antoine Bonamy, live near Laval with their three children

By contrast, Beunel, 41, a social worker, and her husband Antoine Bonamy, 42, a headteacher, get five different streams of state support for Marcel, 2, Laurette, 5, and Leon, 7.

Although state support for children in France is also means-tested, the couple benefit from extended parental leave, which allows Beunel to cut her working hours by 20 per cent and gives them €150 a month to cover some costs.

The couple, who live in a village near Laval in Pays de la Loire, also get about €193 a month that is available to all parents with children under three and a further €340 a month because they have more than two children. They also got about €1,000 in “birth allowance” payments when each child was born.

Although it is difficult to make a direct comparison, particularly given the differences in the tax and benefits rules in the different countries and the varying ages of their children, Elodie is sure her sister’s family get better parental support.

Barron said: “I wasn’t familiar with the benefits system in France, but thinking about all the info my brother-in-law has shared, I feel a bit taken aback by how good the system is. We really don’t get a lot in the UK in comparison.”

Barron visits her sister once or twice a year and they often compare notes about how parents are treated. “One thing that really struck me was that in the UK there tends to be more things to support mothers. There are quite good social structures organised by charities or the church. I remember meeting other mothers with their toddlers on a regular basis. We would have coffee and read to the children. It helps because it can be lonely being a mum to start with. My sister didn’t really have this.”

Barron said there were also cultural differences in attitudes to maternity leave. “Mothers in France tend to go back to work much earlier. My sister took just three months off after Marcel was born. She also had less than six months for the other two. I took a year off for each.”

Bonamy said: “I find the help in France very good. It is means-tested, so some get more than others, but those who have to fund themselves do not find it too much of a burden. Those caring for children under six can also get some of your costs back as a tax deduction. I’m very happy to be in France as a parent.”

Child-unfriendly Britain

Britain has one of the least child-friendly tax systems in the developed world, according to The Lord Farmer, a Conservative peer.

“The UK’s tax system discourages childbearing,” he told parliament in November after a plan to assess child benefit ­eligibility on household rather than individual income, was scrapped.

Making the change, which campaigners including The Sunday Times pushed for, would have cost the government about £1.4 billion a year by 2029 and would have given some 700,000 families an average of about £1,500 a year.

Not making the change, means that single parents earning £80,000 a year will still lose all their child benefit while a couple each earning £59,999 will still be eligible for the full amount.

The Organisation for Economic Co-operation and Development (OECD) compared the equivalents of income tax, national insurance and state benefits in different developed countries. Its Taxing Wages report from 2024 concluded that single people in Britain lost a relatively low slice of their income, including benefits, to tax — 23.6 per cent compared with 24.8 per cent for those in the US, 27.7 per cent in France and 38 per cent in Germany. The average for all OECD countries was 24.7 per cent.

However, for married couples with two children where one parent didn’t work, the share of income including benefits that was lost was 23.1 per cent in the UK, 21 per cent in France and 20 per cent in Germany. In America it was 13.3 per cent, while the average across all developed nations was 19.8 per cent.

Rachael Griffin from the wealth manager Quilter said: “Families in the UK have had to contend with a complicated and often insufficient support system for years. Dual-income households just under the child benefit cap can still get full benefits while single-earner households slightly above the threshold face reductions. This disparity could have been tackled by pegging child benefit to household income under £120,000, rather than individual earners, which is inherently unfair.”

What you get

Parents in the UK can get three benefits: tax-free childcare, free childcare hours and child benefit. While most working couples can claim all three, higher earners often get little help.

Child benefit is worth £25.60 a week for a first child and £16.95 a week for other children — so about £170 every four weeks for two children. For every £200 of adjusted net income (after pension contributions) that one parent earns above £60,000, a family loses 1 per cent of the benefit. By the time they earn £80,000, they get nothing.

Tax-free childcare is a scheme that tops up every £8 you pay in by £2, with the money used to pay for nursery fees and approved nannies and after-school clubs. The top-up is worth up to £2,000 a year per child, but once one parent earns more than £100,000 in adjusted net income, families are no longer eligible.

Working parents can also get 15 free hours a week of childcare during term time for children aged nine months to three years and 30 hours a week for children aged three to four. Higher-earning parents do not get the former and get only 15 free hours for their three to four-year-olds.

From September children from nine months will get 30 free hours a week in term time, but those earning more than £100,000 will still get nothing.

A single parent whose earnings rose above £100,000 could easily find themselves out of pocket. For example, someone with a two-year-old and a nine-month-old whose £99,000 adjusted net income was boosted £2,000 by a bonus or a pay rise would actually be nearly £10,000 worse off. They would lose £400 of their personal income allowance; £4,000 of tax-free childcare; about £3,285 for the loss of 15 free childcare hours for the two-year-old and another £3,444 for the nine-month-old. The parent would also pay an extra £800 in income tax.

This represents an effective marginal tax rate of almost 600 per cent, according to the investment firm AJ Bell.

In France you get a family allowance, which for two children is worth about €148.52 a month, increasing with more children. You also get an early childhood benefit. This includes the birth grant of €1,066.30 and a basic allowance of up to €193.30 a month.

If you employ a nanny or childminder you can get up to €533.96 a month. Families with at least three dependent children can get an extra €93.91 and there is also a means-tested family income supplement of up to €289.98 a month.

Parental leave

In the UK statutory maternity pay is 90 per cent of your average weekly earnings (before tax) for the first six weeks and £184.03 or 90 per cent of your average weekly earnings, (whichever is lower) for the following 33 weeks. It is paid in the same way as your wages (eg monthly or weekly) and tax and national insurance is deducted.

You are eligible if you earn an average of at least £120 a week, give the correct notice, provide proof that you are pregnant and have worked for your employer continuously for at least 26 weeks by the 15th week before your due date. Many companies offer higher maternity pay.

Parental leave allows parents to share time off after having a baby, with up to 39 weeks of shared parental pay. Up to 52 weeks can be taken off work before the child turns one. If you are planning to share paternity leave, the mother (or primary parent) will need to end maternity leave (adoption/surrogacy leave) so the other could start paid parental leave.

In France, standard maternity leave is 16 weeks, including six weeks of prenatal leave before the due date and ten weeks after the birth. Mothers are required to take at least eight weeks’ leave, including six weeks after delivery. Those expecting twins or triplets get longer and mothers who already have two children get 26 weeks of leave for each additional child.

The French state, not the employer, provides maternity pay, paying 100 per cent of the employee’s average daily earnings over the three months before the leave began.