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Working in UK with LtdCO - contract with EU company

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    Working in UK with LtdCO - contract with EU company

    I'm looking to take on a contract for a German company, where I'll be working in the UK.
    I'm expecting to use my own LtdCo which will invoice the client in euros.

    My current accountants haven't been too helpful with advise on any tax implications.

    I'm pretty sure IR35 won't come into it - since if I was thought to be a hidden employee, it would be of the German company, so outside of HMRC's reach (but obv would like to check). Accountants have advised "as as you are UK based company you would have to consider our IR35 perimeters as normal" - which doesn't fill me with confidence!

    In particular, I'd like to check if they are any similar IR35 catches in terms of German taxation laws.

    Any suggestions as to where I can find out such stuff is welcome.

    #2
    If you are working in the UK and resident here yes you do have to look at IR35 as normal.

    Tax law is different from contract law, so while your contract can be under German law your tax obligations are in the UK.

    In regards to VAT if you Google there is info on paying HMRC if your sales are in the EU but you are based in the UK.
    "You’re just a bad memory who doesn’t know when to go away" JR

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      #3
      Thanks - makes sense.

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        #4
        As a side note to this question... Have you checked for sure that you can actually contract through your UK Ltd company in Germany?

        In my experience the majority of UK contractors working with German clients have to go through an umbrella company in Germany.

        They are usually very strict on having taxes paid in Germany rather in other countries.

        Make sure you get some advice for a German accountant so you don't get stung!

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          #5
          A search would be a good start.


          https://www.google.co.uk/search?q=ge...sK6BMSqU6WotGA
          'CUK forum personality of 2011 - Winner - Yes really!!!!

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            #6
            If this is a contract with a German company but you are working in the UK, then it will not be taxed in Germany.

            IR35 can still potentially apply, but due to the fact that the management is in Germany is a pretty strong indicator that you're not like a permanent employee.
            I'm alright Jack

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              #7
              I work at home in the UK on a direct contract with a company in Cyprus. I do have to consider IR35 in the UK but things like supplying my own office and hardware help in that respect. I pay UK CT and PAYE and no tax in Cyprus. VAT is reverse charged. I add no VAT, just a special note on the invoice about an EU directive. The client pays the VAT in Cyprus. I fill in an EU Sales List form on the HMRC website quarterly so that the UK/Cyprus tax authorities can check that the VAT is paid correctly. Germany could be a completely different story though.

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                #8
                Originally posted by javadude View Post
                I work at home in the UK on a direct contract with a company in Cyprus. I do have to consider IR35 in the UK but things like supplying my own office and hardware help in that respect. I pay UK CT and PAYE and no tax in Cyprus. VAT is reverse charged. I add no VAT, just a special note on the invoice about an EU directive. The client pays the VAT in Cyprus. I fill in an EU Sales List form on the HMRC website quarterly so that the UK/Cyprus tax authorities can check that the VAT is paid correctly. Germany could be a completely different story though.
                It will probably be very similar. You need to check about the VAT rules.
                I'm alright Jack

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