Working for a US company in the UK with maybe European work Working for a US company in the UK with maybe European work
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  1. #1

    Nervous Newbie


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    Default Working for a US company in the UK with maybe European work

    I've had a search and can't find anything exactly matching my situation;

    I'm about to embark on a 12 month contract for a US firm , via a US agency who will (I think) be paying me direct in dollars.

    The work itself will be in Denmark and will involve being in Denmark Monday to Thursday then back in the UK Friday to Sunday.

    I have a UK based limited company.

    Has anyone been through something similar and if so are there any tips or tax implications I need to be aware of.

    Many thanks :-)

  2. #2

    I live on CUK

    SueEllen's Avatar
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    Go online and Google the Danish tax office. Being a Nordic country they should have some of their tax pages translated into English.

    There is a poster currently working in Denmark but he's there all the time.
    "You’re just a bad memory who doesn’t know when to go away" JR

  3. #3

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    Quote Originally Posted by SueEllen View Post
    Go online and Google the Danish tax office. Being a Nordic country they should have some of their tax pages translated into English.

    There is a poster currently working in Denmark but he's there all the time.
    That's me!

    I'm resident in Denmark, currently back in UK for a few days but in order not to be tax resident in UK I can only be in UK for 91 days per annum, and there's a lot of other tests too so not as easy as that...

    You can't trade via your UK limited in Denmark, that's a certainty. WRT to the US company you'll need to do some legwork, (or they will). I'd guess you'll need to trade via local payroll company who can avail you of the Danish ETS (Expat Tax Scheme) which is effectively 30% tax. Of course you will be subject to UK tax as well since rates for DA will put you well into the UK 40% and possibly the higher one so you need to be prepared for that or not be UK tax resident.

    I'll dig out some links tomorrow but the three most important things are The State Administration Office, for EU residency, The International Office for CPR number (ie Danish NINO) and SKAT for tax but if you go local payroll your Nordic payroll people will sort that. NEVER NEVER register at Internation House for tax, they will try to help but put you on ordinary tax, which can be as high as 86%.....

    Be prepared to be stay in each office half a day at least each, can't be done online. After that you'll need a NEMid which is a bit like a government gateway account in UK. You have to have one if resident and you'll need a place (hard to find) because hotels are freakishly expensive...

    Remember that unlike Sweden the Danes will tax you as local from day one.

    It's a nightmare at first but worth it because it's a great place to live especially CpH, best thing I ever did....

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    I live on CUK

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    Quote Originally Posted by stek View Post
    That's me!
    Nice of you to pop along and answer the OP.
    "You’re just a bad memory who doesn’t know when to go away" JR

  5. #5

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    So I'm curious. Will the OP actually be "trading" in Denmark? Isn't he trading in the UK and just being in Denmark 4 days a week?

    I'm curious simply because I also work for a US company via a US agency, trading using my UK LtdCo, but to be fair do my stuff sat here in the UK. So I know it's not the same situation, I'm just being nosey

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    Quote Originally Posted by Platypus View Post
    So I'm curious. Will the OP actually be "trading" in Denmark? Isn't he trading in the UK and just being in Denmark 4 days a week?

    I'm curious simply because I also work for a US company via a US agency, trading using my UK LtdCo, but to be fair do my stuff sat here in the UK. So I know it's not the same situation, I'm just being nosey
    The golden rule is tax is due where the work is done and you have to say that makes perfect sense.

    It's my mantra, stick with it and there will be no tax woes, just look at the guy on here who did 30 days via UK ltd in Norway, his world of pain is just starting....

  7. #7

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    Thanks for all the replies - seems I've got some work to do !

    I've worked in Switzerland before - I was there for a year and a half working for UBS - I paid Swiss tax and that seemed sensible as I was being paid by a Swiss company.

    However in this case I will be out of the UK for about 160 days (the contract is 11 months, 4 days a week, some holidays - so about 40 weeks of 4 days)

    Isn't there a "180 day rule" which says I'm resident in the UK if I'm there for over 180ish days ?

    Also - I'm being paid by the US company - the client in Denmark pay the US company and they pay me - doesn't that change things?

  8. #8

    bored now

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    Quote Originally Posted by gremlinsky View Post
    Thanks for all the replies - seems I've got some work to do !

    I've worked in Switzerland before - I was there for a year and a half working for UBS - I paid Swiss tax and that seemed sensible as I was being paid by a Swiss company.

    However in this case I will be out of the UK for about 160 days (the contract is 11 months, 4 days a week, some holidays - so about 40 weeks of 4 days)

    Isn't there a "180 day rule" which says I'm resident in the UK if I'm there for over 180ish days ?

    Also - I'm being paid by the US company - the client in Denmark pay the US company and they pay me - doesn't that change things?
    Yes it makes things that were already complex and difficult to work out far more complex and even more difficult to work out....

    All that 180 day thing does is confirm that you need to pay tax in the UK, it doesn't mean that you can skip paying tax in Denmark....

    You really need specialist advice here if you were going to go ahead with this and that advice isn't going to be cheap....
    merely at clientco for the entertainment

  9. #9

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    Quote Originally Posted by gremlinsky View Post
    Thanks for all the replies - seems I've got some work to do !

    I've worked in Switzerland before - I was there for a year and a half working for UBS - I paid Swiss tax and that seemed sensible as I was being paid by a Swiss company.

    However in this case I will be out of the UK for about 160 days (the contract is 11 months, 4 days a week, some holidays - so about 40 weeks of 4 days)

    Isn't there a "180 day rule" which says I'm resident in the UK if I'm there for over 180ish days ?

    Also - I'm being paid by the US company - the client in Denmark pay the US company and they pay me - doesn't that change things?
    It may be fewer days than that. Usually, a day where you are not there on midnight is not counted. So, arriving on Monday am and leaving Thursday pm usually counts as three days, not four.

  10. #10

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    Quote Originally Posted by gremlinsky View Post
    Thanks for all the replies - seems I've got some work to do !

    I've worked in Switzerland before - I was there for a year and a half working for UBS - I paid Swiss tax and that seemed sensible as I was being paid by a Swiss company.

    However in this case I will be out of the UK for about 160 days (the contract is 11 months, 4 days a week, some holidays - so about 40 weeks of 4 days)

    Isn't there a "180 day rule" which says I'm resident in the UK if I'm there for over 180ish days ?

    Also - I'm being paid by the US company - the client in Denmark pay the US company and they pay me - doesn't that change things?
    Nah, it's way more complicated than that. Here's the guidance for the UK statutory residence test:

    https://www.gov.uk/government/upload...nal_078500.pdf

    Essentially, it's very difficult to avoid UK residency now (since 2014). Also, note the difference between the tax residency of your company and your personal tax residency. One of the problems with maintaining a UK Ltd. (regardless of whether you use it) is that corporate residency tends to follow the residency of the controlling persons, which can lead to a world of hurt unless you know what you're doing.

    The first general rule is that you pay tax where the work is performed. The second general rule is that, after accounting for tax treaty benefits, you typically pay the higher of the marginal rates in the countries where you're resident, i.e. you would have a residual tax bill in the UK. Unless you have a strong need to remain resident in the UK, you'd be better off working full time in Denmark. That way, you'll meet the "third automatic overseas test" (i.e. not UK tax resident), but you need to be very mindful about the number of trips back and your other ties to the UK. As I say, it's now rather difficult to lose UK tax residency once you have it.

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