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183 day and German Company to Umbrella or Not ?

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    183 day and German Company to Umbrella or Not ?

    Hello there
    An interesting use case here that I thought you might be able to help shed some light on. For the best approach on whether to use an umbrella or not, and implication of going over 183 days in the host country if not going with umbrella

    Background
    German Company with employees (not one man shop)
    Employee will be seconded to the UK initially 3 months
    Employee is Tax resident in Germany ( personal and economic ties are there)
    Employee also happens to be the MD for said German company, a salaried position

    Assumptions
    Income Tax, Social Security will still be paid in Germany for employee
    Corp Tax and ( all those additional German business Taxes) also paid in Germany
    Start Date is 1s December (for example)


    Whilst Umbrella would be the easiest way , it may not be the most tax efficient ?
    What additional liabilities am i missing ?
    what happens if work continues over 183 days ? Employee is still Tax-resident in Germany ( double taxation nightmares)


    Thanks in advance
    renyle

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