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Where Taxpayers and Advisers Meet

Moving Around Multiple Countries

fatlad
Posts:1
Joined:Thu Jan 20, 2022 11:26 am
Moving Around Multiple Countries

Postby fatlad » Thu Jan 20, 2022 11:52 am

Hi all,

My first post, so please be gentle. Hopefully this is the right forum. I'm looking for some confirmation really as i've searched the site but struggled to find advice on this specific point. I work for a UK company and get paid into a UK bank account in sterling and pay all my tax in the UK. However, I've been moving back and forward between France, working remotely, and the UK, making sure not to spend more than 90 days in any 180 in France, to avoid any tax implications.

This year, I'm looking to go to France for 90 days, then to Spain for 90, then back to France for 90 then back to the UK, which means I'll be out of the UK for most of the year but not in any one country for more than 90 days in any 180. From what I've found online and I understand, in this situation tax is paid where you have your main assets and ties. For me that would still be the UK I believe. Am I understanding this right? I need to avoid creating any tax implications in other countries. Thanks in advance for your help.

darthblingbling
Posts:496
Joined:Wed Aug 02, 2017 9:09 pm

Re: Moving Around Multiple Countries

Postby darthblingbling » Thu Jan 20, 2022 12:37 pm

You have to first consider your tax residency under the domestic rules of each country which can vary significantly. If you are resident in multiple for the same periods then you need to consider the tax treaties.

I'd you have home in the UK that is always available to you and no home elsewhere, it will be relatively comfortable to say that you are resident in the UK for tax under our domestic legislation and if you were resident in another jurisdiction then under treaty you would remain treaty resident in the UK as you have a permanent home in the UK only. Caveat that home has a relatively wide meaning and doesn't just refer to you owning property.

darthblingbling
Posts:496
Joined:Wed Aug 02, 2017 9:09 pm

Re: Moving Around Multiple Countries

Postby darthblingbling » Thu Jan 20, 2022 12:47 pm

I should note that being non resident doesn't automatically make you not liable for tax in that jurisdiction.

Generally speaking employment income is taxable where the work is exercised on a day to day basis. If you're non resident in France they may seek to tax the portion of your employment income that relates to the French workdays. If you remain tax resident in the UK then you are taxed on your worldwide income and would need to consider how to claim relief on the double taxed income. The treaty in some cases may exempt it in the non resident country, but this is not always the case.

You will also need to consider social security, but fortunately within the EU and UK that is relatively simpler. Have a Google on multi state worker rules.

Your movements may also have tax implications for your employer so you should discuss your movements with them.


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