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Where Taxpayers and Advisers Meet

Resident in Germany but working in UK

leodaly123
Posts:1
Joined:Tue Feb 16, 2021 10:38 am
Resident in Germany but working in UK

Postby leodaly123 » Tue Feb 16, 2021 10:42 am

Good Morning,

A friend of mine is German and lives/works there at present. He has received an offer from a UK based company where it has been agreed that he will work in the London office 2/3 days per week throughout the year. They will be applying for his Tier 2 VISA but my friend has a concern with regards to the tax he will be paying. He has heard of the Double Taxation Agreement, however, I am not sure if this still stands as the UK is no longer in the EU.

Will he have to pay tax in both Germany and the UK or is their a way around this?

Any help would be much appreciated.

Best wishes
Liam

AGoodman
Posts:1738
Joined:Fri May 16, 2014 3:47 pm

Re: Resident in Germany but working in UK

Postby AGoodman » Wed Feb 24, 2021 3:24 pm

He will likely be tax resident in both countries so will need to look at Article 14 of the double tax treaty. This should be unaffected by Brexit. It sounds likely that he will be Treaty Resident in Germany.

From what you have said, he will have to pay UK tax on his UK role but should avoid UK tax on any job back in Germany. He should get credit in Germany for the tax he pays there.

If he will be UK tax resident under UK domestic law (which is likely), he will also need to consider any other forms of income he receives .

Finally, there's a national insurance aspect but I cant really help you there. His new UK employer's advisers may be able to help.

darthblingbling
Posts:698
Joined:Wed Aug 02, 2017 9:09 pm

Re: Resident in Germany but working in UK

Postby darthblingbling » Wed Feb 24, 2021 5:51 pm

If he is working at least 2 days a week in Germany (and is habitually resident there), then under multi state rules, even under the new agreement post brexit he should likely be subject only to German Social Security. He should ensure he gets an A1 from the German Authorities tho to certify this.

darthblingbling
Posts:698
Joined:Wed Aug 02, 2017 9:09 pm

Re: Resident in Germany but working in UK

Postby darthblingbling » Wed Feb 24, 2021 5:53 pm

Saying that, his UK employer will need to be aware that they may need to operate a payroll in Germany to operate social security and potentially income tax withholding.


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