Image caption EU immigrants can gain access to a range of UK state benefits if they pass a residence test

The UK is examining ways to claw back welfare payments made to migrants from other EU countries from their home government, the BBC understands.

A levy could be put in place so that for the first two years that a migrant was in the UK, the government would be able to reclaim any benefits paid out.

The arrangement was used until the 1990s, when the EU had fewer members.

A Foreign Office source said officials were checking if it was "possible to return to the system".

People coming to the UK from the European Economic Area - the EU member states and Iceland, Liechtenstein and Norway - do not have unrestricted access to social security benefits and tax credits.

Most have to pass the habitual residence test before they can claim. To do so, they must have a "right to reside" in the UK, which means you are economically active, or are able to support yourself, and you must be intending to settle for the time being - to be "habitually resident".

'Clear message'

Those who pass the test can claim housing benefit, council tax benefit, access to local authority housing, income support, Jobseeker's Allowance and Employment and Support Allowance.

Re-introducing a system of national refunds for benefits claims "might not raise huge sums," the senior Foreign Office source said, "but it would send a clear message about who is picking up the bill for these people".

It is understood Whitehall officials acknowledge that reverting to an approach previously used two decades ago may no longer be practical given EU expansion and changes to European law since then, but it is regarded as worth exploring.

In January 2014, restrictions that have applied to migrants from Romania and Bulgaria to the UK will expire.

Meanwhile, the UK is being taken to court by the European Commission for allegedly discriminating against EU nationals who claim social security in the UK.

It is alleged the extra UK "right to reside" test to see if migrants are eligible to claim breaches EU law. The government has said it will fight the court case robustly.

Ministers are keen to be seen to be adopting a muscular approach to immigration, given how big a priority opinion polls suggest it is to many voters, and the recent strong performances of the UK Independence Party.