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Dual Citizen moving to the UK

Dual Citizen moving to the UK

Old Jul 12th 2017, 2:51 am
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Default 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?
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Old Jul 12th 2017, 3:38 am
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Default Re: Dual Citizen moving to the UK

Originally Posted by BigBgoh
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?
Hi BigBgoh

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.
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Old Jul 12th 2017, 3:43 am
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Default 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.
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Old Jul 12th 2017, 3:52 am
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Default Re: Dual Citizen moving to the UK

Originally Posted by Pulaski
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.
With all due respect, it's much more complicated than this, residency for tax purposes needs to be determined and that isn't always as clear cut as it sounds in this situation trust me. In addition to this it's about all your possible sources of income, not just that which you receive from your employer. Given the OPs situation it sounds likely they may be spending time travelling between the two and it matters how much time you spend in each country during the tax year - I am in the same situation as the OP and for example I have to keep a daily travel diary for tax purposes each year. It's hard to provide advice without knowing how the company is set up there are many different ways it can work and they don't all have the same implications.
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Old Jul 12th 2017, 4:33 am
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Default 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.
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Old Jul 12th 2017, 4:35 am
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Default Re: Dual Citizen moving to the UK

Originally Posted by BigBgoh
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.
Will you be being paid in GBP or USD if you are being employed by the US? My original advice still stands - these things are highly complex and more than they might seem and professional advice would be wise so you don't get tripped up on something you didn't know.
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Old Jul 12th 2017, 4:37 am
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Default Re: Dual Citizen moving to the UK

Originally Posted by Missl73
Will you be being paid in GBP or USD if you are being employed by the US? My original advice still stands - these things are highly complex and more than they might seem and professional advice would be wise so you don't get tripped up on something you didn't know.
I will seek out professional advice for sure.

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.
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Old Jul 12th 2017, 4:39 am
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Default Re: Dual Citizen moving to the UK

Originally Posted by BigBgoh
I will seek out professional advice for sure.

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.
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.
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Old Jul 12th 2017, 4:42 am
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Default 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.
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Old Jul 12th 2017, 4:47 am
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Default Re: Dual Citizen moving to the UK

Originally Posted by BigBgoh
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.
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.
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Old Jul 12th 2017, 4:48 am
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Default 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.
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Old Jul 12th 2017, 4:53 am
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Default 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?
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Old Jul 12th 2017, 4:53 am
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Default Re: Dual Citizen moving to the UK

Originally Posted by Missl73
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.
Thank you so much!
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Old Jul 12th 2017, 4:53 am
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Default Re: Dual Citizen moving to the UK

Originally Posted by scot47
Most countries have Double Taxation Agreements - designed to avoid the need to pay tax in two jurisdictions. You need a competent accountant.
Correct here's the one between UK and US https://www.gov.uk/government/publications/usa-tax-treaties

I agree with Scot47 you need a good accountant to interpret it for your individual situation.
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Old Jul 12th 2017, 4:54 am
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Default Re: Dual Citizen moving to the UK

Originally Posted by BigBgoh
Thank you so much!
You're welcome I've been there and been stung. I hope you get it all sorted
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