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Tax - UK contracting then USA employee for same company

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    Tax - UK contracting then USA employee for same company

    Hi all,

    I've agreed an offer for a job in USA. It's dependent on a visa and COVID travel restrictions being lifted so tentative start date is later this year. In the meantime I will start contracting for this company from the UK for which I've got two options: 1) set up a Ltd company or 2) work through an umbrella company.

    For the Ltd company: I've read about withholding tax being applied at source unless filling out a W8-BEN form, although I'm not sure if this will apply to me if I setup a UK Ltd company for this contracting - I think my company should just get paid the full without any withholding tax, is that right? However, if I then move to the USA and work for that same client as an employee during the same US tax year I presume things could get messy. I can't imagine this is a unique case, after all contractors become employees fairly routinely in various ways, so I hope that someone here has some experience or some knowledge of how this will work in practice.

    If I use an umbrella company they'll pay me as PAYE in the UK and I'll obviously pay more tax, but I think there won't be any confusion with the USA tax situation when we later move to the USA. If anyone knows different please tell!

    Final possibly relevant point: we've been living and working in France for the past few years so I'm not currently resident in the UK, only moving to the UK to start this contracting. This means I'll be resident in France, UK and USA during the same tax year! (whoops!).

    I've been trying to find an accountant(s) who can help me with this but so far I've only found ones who can do the UK part, not also advise or assist on the USA part nor the French part. If anyone knows a firm who can definitely help with at two or ideally three parts of this then please tell me.

    Cheers

    #2
    When you move you need to make sure you deregister. Both France and the UK take a split year approach. You are only taxed on the income in France up until the date you left and you are only taxed on income in the UK from the date you arrive. If you are living in France I would pay a visit to a French accountant. They can then also handle queries from the French tax authorities after you've left. When I've worked across borders I've had two accountants. It's the only feasible way.
    Last edited by BlasterBates; 30 May 2021, 08:19.
    I'm alright Jack

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      #3
      Hi BlasterBates,
      Thanks for your reply, please excuse me long delay in replying. Thank you for the advice, that's the conclusion I've come to as well. I already have a tax assistant in France so now just need to find a good UK one and a good USA one.
      Cheers

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