Tax considerations when moving abroad

There are many things to consider when moving to work and live abroad - organising a visa, a job, accommodation in the foreign country but by obtaining some sound tax advice before leaving your home country, often you can minimise your taxes also.

General Tax consideration:

1.       Residency & Domicile  – A person will normally be deemed tax resident if they live in a country for 183 days or more within a particular tax year. However, your home, place of economic ties, number of days in the country in the previous year/ subsequent years and other factors may also be taken into consideration when determining place of residence.
Where tax year-ends differ eg Ireland’s tax year is Jan-Dec, the UK’s tax year is 6th April – 5th April, you may find you are resident in both countries. The double taxation agreements between the two countries set out the rules to determine where you are ultimately considered tax resident.
Why is residency & domicile an issue? Residency will generally determine when, where and how income is taxed. Certain income types are taxed in the country of residence eg employment income. However other income eg rental income/capital gain on property is generally taxed in the country where the property is situated. Tax rules may subject such income to tax in both countries. If you are a US citizen you are taxed on your worldwide income in the US regardless of where you reside.

2.       Double taxation Relief – where there is a double taxation agreement between your home country and your proposed new country of residence, double taxation relief may apply which will eliminate double taxation. You may still be obliged to file a tax return in both countries but will be able to offset tax payable in one country against tax payable on the same income in the second country.

3.       Tax refund: if you worked a short year in your home country and did not claim all your allowances/reliefs, you should check if you are due a tax refund before you leave. Likewise before or when you leave the foreign country and return home.

4.       Property Tax considerations : generally income from property is subject to tax in the country where the property is located but may be subject to tax in more than one country (see double taxation relief above). Considerations include: tax on rental income (non-resident landlord / NRL), capital gains, CAT, Principal Private Residence relief, annual rates/ local taxes, PRTB registration and first time buyers stamp duty exemption. Similar tax issues apply if you are considering buying a property abroad. Contact us at info@dgitax.com for further details.

5.       Application for a Tax ID: a country specific Tax ID is required if you want to work in that country. You should apply for a Tax ID as soon as possible. (Irish PPS No., UK NIC No., US ITIN, Oz TFN or ABN, Canadian ITN, German Steuer Nr.).

6.      Total Taxes on income
When deciding which country or State within a country you will work, consider all relevant taxes:
Employee:
Federal tax, State tax and Social security taxes eg PRSI, UK NIC, Oz Superannuation & Medicare, Canadian  SIN & USA SSI
Self Employed taxes: income tax, corporate tax, trade tax, VAT / GST, Sales tax etc.
Other taxes: Wealth tax, Capital Gains Tax, Inheritance Tax, Investment withholding tax

7.       Social Security taxes & cover: avoid paying double social security taxes but ensure you are still covered.

 

DG International Tax can advise you on the above and other tax issues arising when moving abroad.

Please contact us at info@dgitax.com for further details

on the Tax Implications of:

Moving to work in Australia

Moving to work in Canada

Moving to work in Germany

Moving to work in Ireland

Moving to work in the UK

Moving to work in the USA 

Click here for more on setting up a business in Ireland

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