Need some tax advice, anybody have a good adviser?
Discussion
Especially if you know anybody with good knoweldge of UK and Irish tax law... (Wait for everybody to saw EricMc!)
I am domiciled in the UK (through birth) and worked in the UK until June 2007 when I moved to the ROI to work there. Whilst working for the same multinational, I effectively ceased employment with the UK Ltd company to join the Irish Ltd. company. I'm a permanent employee taxed in Ireland. I have lived in here since June 2007 to present with very limited travel back to the UK (4-5 weeks in total over two years)
I am considering the possibility of moving back to the UK this year. One scenario under consideration is remaining working for (and paid by) my current Irish employer, but working remotely. I would effectively be a home worker with fairly limited trips over to Ireland (e.g. 2-3 days per month)
I own no property or have any other significant assets in either the UK or Ireland. I am married, my wife is Irish and would likely be employed in the UK if we move over. No kids.
I've been reading up, but have a few questions on the tax implications of the above option:
- I will effectively continue to be paid by my Irish employer and pay Irish tax at source. However, almost all of my income will be transferred back to the UK. How will this play out in terms of UK taxation?
- What are the implications of the fact that I will actually be working from the UK, as opposed to just being resident in the UK but commuting and carrying out my work in Ireland? From what I've read of the UK/Ireland DTA this isn't going to help me and may be the deal-breaker for such an arrangement.
- What are the implications of the fact that my employer is a multinational company with offices in the UK and Ireland? Does the fact that the Irish and UK companies are distinct limited companies have any bearing?
I want to get some advice from a specialist, so this thread is more about recommendations rather than looking for answers, but the PH collective can bring useful information to bear then so much the better :-)
I am domiciled in the UK (through birth) and worked in the UK until June 2007 when I moved to the ROI to work there. Whilst working for the same multinational, I effectively ceased employment with the UK Ltd company to join the Irish Ltd. company. I'm a permanent employee taxed in Ireland. I have lived in here since June 2007 to present with very limited travel back to the UK (4-5 weeks in total over two years)
I am considering the possibility of moving back to the UK this year. One scenario under consideration is remaining working for (and paid by) my current Irish employer, but working remotely. I would effectively be a home worker with fairly limited trips over to Ireland (e.g. 2-3 days per month)
I own no property or have any other significant assets in either the UK or Ireland. I am married, my wife is Irish and would likely be employed in the UK if we move over. No kids.
I've been reading up, but have a few questions on the tax implications of the above option:
- I will effectively continue to be paid by my Irish employer and pay Irish tax at source. However, almost all of my income will be transferred back to the UK. How will this play out in terms of UK taxation?
- What are the implications of the fact that I will actually be working from the UK, as opposed to just being resident in the UK but commuting and carrying out my work in Ireland? From what I've read of the UK/Ireland DTA this isn't going to help me and may be the deal-breaker for such an arrangement.
- What are the implications of the fact that my employer is a multinational company with offices in the UK and Ireland? Does the fact that the Irish and UK companies are distinct limited companies have any bearing?
I want to get some advice from a specialist, so this thread is more about recommendations rather than looking for answers, but the PH collective can bring useful information to bear then so much the better :-)
If you move permanently back to the UK you will become a UK tax resident. Therefore, all your income from all worldwide sources will be subject to UK tax.
If the Irish company retains you on their Irish payroll, they will probably deduct Irish PAYE tax (and possibly Irish PRSI as well - plus some of the other deductions they have over there).
You will still be liable to UK tax on the gross income from the Irish employer but you will be given a Tax Credit against any UK tax amounts due. The net effect is that you may not have tro pay any UK tax on this income - although you will, in all probability, need to complete a UK Self Assessment tax return at the end of each tax year.
The situation vis a vis Irish PRSI and UK NI is complex and you may need additional advice on this. Irish PRSI will entitle you, eventually, to an Irish state pensionm. You may not want this and you may want to rteinstate your NI contributions in the UK to ensure you obtain a UK state pension when you eventually retire.
Finally, if you are being paid directly from Ireland your income levels will be subject to currency fluctuations between the Euro and Sterling - which may or may not be a problem for you.
If the Irish company retains you on their Irish payroll, they will probably deduct Irish PAYE tax (and possibly Irish PRSI as well - plus some of the other deductions they have over there).
You will still be liable to UK tax on the gross income from the Irish employer but you will be given a Tax Credit against any UK tax amounts due. The net effect is that you may not have tro pay any UK tax on this income - although you will, in all probability, need to complete a UK Self Assessment tax return at the end of each tax year.
The situation vis a vis Irish PRSI and UK NI is complex and you may need additional advice on this. Irish PRSI will entitle you, eventually, to an Irish state pensionm. You may not want this and you may want to rteinstate your NI contributions in the UK to ensure you obtain a UK state pension when you eventually retire.
Finally, if you are being paid directly from Ireland your income levels will be subject to currency fluctuations between the Euro and Sterling - which may or may not be a problem for you.
Incidentally, from what I've read there is no PRSI equivalent to the UK SERPS opt-out. I would certainly want to pay voluntary UK NI contributions (and pay the backdated contributions from June 2007)
So, I'd be in the situation of:
Paying ROI income tax
Paying full ROI PRSI
Paying the income levy
Having to continue to pay into my Irish company pension to avail of the employer contributions
Not continuing company subsidised health insurance which I would not be in a position to use
Pay voluntary UK NICs
Take out (or not) private health insurance in the UK
Think about a private UK pension as well (or other vehicles)
Be subject to the whims of the €/£ exchange rate (although a UK based € account will help here a bit)
Not looking like an option really.
So, I'd be in the situation of:
Paying ROI income tax
Paying full ROI PRSI
Paying the income levy
Having to continue to pay into my Irish company pension to avail of the employer contributions
Not continuing company subsidised health insurance which I would not be in a position to use
Pay voluntary UK NICs
Take out (or not) private health insurance in the UK
Think about a private UK pension as well (or other vehicles)
Be subject to the whims of the €/£ exchange rate (although a UK based € account will help here a bit)
Not looking like an option really.
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