Structure for working abroad

Structure for working abroad

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Hello,

I’m just looking for an opinion on best income structure when working abroad.

 I have a client working overseas paying tax in the country where employed. However the client has previously been able to claim non-residency yet now wishes to reside in the UK and continue working abroad.

Any suggestions on best scenario income circa 100k taxed at approx’ same rate as UK (NI difference) employed by company trading add’ in the UK, reg’ add’ USA.

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By Expat24
05th Aug 2013 12:04

Curious about the phrase 

Curious about the phrase  "wishes to reside in the UK and continue working abroad".....  if he is still  spending time abroad to perform his duties, then chances are, he will continue to be resident in that country under their domestic legislation and if he meets the tests under the SRT to trigger residence in the UK, then he could be dual resident.  In that case you are in to the realms of the DTA Article 4 treaty tie break but beware that other Articles of a DTA can still give primary taxing rights to the overseas jurisdiction. You say he is "employed" already so how much flexibility has he got?  If this jurisdiction is the US, you need to worry about lots of things before meddling - visa/work permit issues, non-US corporate structures are obliged to make special reporting returns, etc etc  If it is Europe, beware of taking him out of an 3rd party employment into his own company's employ and being left with ers & ees foreign social security liabilities!! .

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