Dual Citizen moving to the UK
#1
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Dual Citizen moving to the UK
I have been searching a lot of the forums and can't find anything specific to my situation (surprisingly)
I am a dual citizen (US/UK) and just got a promotion to head our expansion to the UK. I will be receiving a salary from both the US and UK, I am still heavily involved in our US operations, and I'm confused how tax works.
Company A is in the US.
Company B is in the UK.
Do I file Company A and B both as US income, or do I file Company A in the US as a US citizen and Company B in the UK as a UK citizen.
Also, does anyone have any recommendations on car insurance companies for UK Citizens driving on a US drivers license?
I am a dual citizen (US/UK) and just got a promotion to head our expansion to the UK. I will be receiving a salary from both the US and UK, I am still heavily involved in our US operations, and I'm confused how tax works.
Company A is in the US.
Company B is in the UK.
Do I file Company A and B both as US income, or do I file Company A in the US as a US citizen and Company B in the UK as a UK citizen.
Also, does anyone have any recommendations on car insurance companies for UK Citizens driving on a US drivers license?
#2
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Joined: Jun 2017
Posts: 30
Re: Dual Citizen moving to the UK
I have been searching a lot of the forums and can't find anything specific to my situation (surprisingly)
I am a dual citizen (US/UK) and just got a promotion to head our expansion to the UK. I will be receiving a salary from both the US and UK, I am still heavily involved in our US operations, and I'm confused how tax works.
Company A is in the US.
Company B is in the UK.
Do I file Company A and B both as US income, or do I file Company A in the US as a US citizen and Company B in the UK as a UK citizen.
Also, does anyone have any recommendations on car insurance companies for UK Citizens driving on a US drivers license?
I am a dual citizen (US/UK) and just got a promotion to head our expansion to the UK. I will be receiving a salary from both the US and UK, I am still heavily involved in our US operations, and I'm confused how tax works.
Company A is in the US.
Company B is in the UK.
Do I file Company A and B both as US income, or do I file Company A in the US as a US citizen and Company B in the UK as a UK citizen.
Also, does anyone have any recommendations on car insurance companies for UK Citizens driving on a US drivers license?
I strongly recommend you ask your company to pay for professional tax advice. I have been in this situation twice (am about to again where I will be earning AUD working for my Australian company but physically based in the UK). In my experience I had to file tax returns in both countries every year. Its less about your citizenship, I don't think that matters, what matters is which country you are deemed to be a resident of for tax purposes (and in situations like this that in itself can be complex to work out). Ultimately you should know it's quite possible you can end up paying tax on the same income in both, for this reason my company (a large multi-national) offer a tax equalisation protection clause in my contract should this happen.
I've had two 2 hour long briefings with PwC (one in my "home" country Australia and one in my "placement" country the UK) who are handling all my tax affairs related to my move and the long and short of it is it's very complex. They will also need to understand if you have any other sources of income for example from shares or property and in which country those are held - there can be capital gains tax implications.
There are dual tax agreements between certain countries, information on the treaty between the UK and US can be found here: https://www.gov.uk/government/publications/usa-tax-treaties But unless you are very knowledgable about tax these documents can be hard to understand!!
Seeking professional help can be expensive but I really think it's in your best interests to do so. I hope this helps!!
Last edited by Missl73; Jul 12th 2017 at 3:45 am.
#3
Re: Dual Citizen moving to the UK
You pay income and payroll taxes where you work; where you are paid and who pays you is irrelevant.
The only workable solution is for the company where you are actually living and working pays you the total amount you are paid, AND pays the total income tax and other deductions due where you are living so NI if you are in the UK. Then the US company pays/credits the UK company through an intercom any account.
The only workable solution is for the company where you are actually living and working pays you the total amount you are paid, AND pays the total income tax and other deductions due where you are living so NI if you are in the UK. Then the US company pays/credits the UK company through an intercom any account.
#4
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Joined: Jun 2017
Posts: 30
Re: Dual Citizen moving to the UK
You pay income and payroll taxes where you work; where you are paid and who pays you is irrelevant.
The only workable solution is for the company where you are actually living and working pays you the total amount you are paid, AND pays the total income tax and other deductions due where you are living so NI if you are in the UK. Then the US company pays/credits the UK company through an intercom any account.
The only workable solution is for the company where you are actually living and working pays you the total amount you are paid, AND pays the total income tax and other deductions due where you are living so NI if you are in the UK. Then the US company pays/credits the UK company through an intercom any account.
#5
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Re: Dual Citizen moving to the UK
Not do go too deep in. The company in the US (Company A) is a global brand, but still relegated to selling outside Europe. Company B (UK) being a separate entity, almost like a franchise, but we are still selling the same products and pushing the same brand. I will be employed by the larger brand (US Company A) and heading the start up in the separate venture (Company B UK) and relocating full time to the UK.
#6
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Re: Dual Citizen moving to the UK
Not do go too deep in. The company in the US (Company A) is a global brand, but still relegated to selling outside Europe. Company B (UK) being a separate entity, almost like a franchise, but we are still selling the same products and pushing the same brand. I will be employed by the larger brand (US Company A) and heading the start up in the separate venture (Company B UK) and relocating full time to the UK.
#7
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Re: Dual Citizen moving to the UK
I will be paid in USD from the US company that will be deposited to my US bank account. I will be paid in GBP from the UK company that will be deposited into my UK Bank account.
#8
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Re: Dual Citizen moving to the UK
Then you will definitely have to complete tax returns in both countries. Advise on what do with any other income assets you have will also be helpful eg if you own a property or shares or have any other sources of income outside of your job.
#9
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Re: Dual Citizen moving to the UK
I was just thinking if I'm earning $100K to my US account, and $30k to my UK account, will I pay $130k in both US and UK??
Thats a lot of tax....
EDIT- essentially taxed twice on the same amount.
Thats a lot of tax....
EDIT- essentially taxed twice on the same amount.
#10
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Re: Dual Citizen moving to the UK
It can get messy so you and our company need to be well informed on the implications - particularly you as an individual as you are the one responsible for the tax you pay so it could disadvantage you if not set up correctly.
#11
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Re: Dual Citizen moving to the UK
Most countries have Double Taxation Agreements - designed to avoid the need to pay tax in two jurisdictions. You need a competent accountant.
#12
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Re: Dual Citizen moving to the UK
Ok, so professional help is key.
Also, anyone know a place to get insurance on a US drivers license? I know Direct Line had said they would insure me, however on a "run of the mill car" which I'm not sure what that means. Any recommendations for exotic cars?
Also, anyone know a place to get insurance on a US drivers license? I know Direct Line had said they would insure me, however on a "run of the mill car" which I'm not sure what that means. Any recommendations for exotic cars?
#13
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Re: Dual Citizen moving to the UK
I'm not an expert enough to know exactly how it works afraid, but I do know that yes there is a risk of being taxed in both countries on the same income (eg the $130k) that's why you need proper advice which will include establishing which country you will be considered a resident in for tax purposes - for example I'm considered an Australian tax resident even though I live in the U.K.
It can get messy so you and our company need to be well informed on the implications - particularly you as an individual as you are the one responsible for the tax you pay so it could disadvantage you if not set up correctly.
It can get messy so you and our company need to be well informed on the implications - particularly you as an individual as you are the one responsible for the tax you pay so it could disadvantage you if not set up correctly.
#14
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Re: Dual Citizen moving to the UK
I agree with Scot47 you need a good accountant to interpret it for your individual situation.