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need some dual tax specialists

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    #11
    Originally posted by Clare@InTouch View Post
    You need a specialist, rather than a general practice accountant. Try someone like these guys (Haines Watts): Haines Watts - Chartered Accountants, VAT, Business Services
    Thanks I will give them a call.. Has anyone used them?

    I have hired accountants who have not really had the knowledge, I dont want to make the same mistake again

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      #12
      Originally posted by BlasterBates View Post
      Normally when you earn in two countries, the simple principle is that you are taxed on income you get from country 1 inc country 1 and income you get from country 2 in country 2. Now this is the bit where you are probably failing. You will be mainly resident in one country or the other but not both. In the country where you are mainly resident you declare the income from the other country and it may or may not be taxed again depending on complicated rules, but it shouldn't be fully taxed again.

      You need advice from a UK accountant and he should handle the tax affairs from the UK perspective. You then need a Swedish accountant and he should deal with it from the Swedish perspective.

      You need to establish where you are fully resident, then probably you need to claim tax back where you are not. There is probably a clause in the DTA that states when it is unclear the tax authorities will agree with each other.

      Can you be more explicit about why you think you're paying too much tax. Who is taxing you and at what rate?

      You ought to figure out yourself roughly where it's going wrong. In particular where you are taxed at the full rate and you've already been taxed in the other country, i.e. you are paying the full rate of tax on something in both countries.

      Other than that it is probably correct, but definitely worth checking.

      There are some fundamental questions I have about this..

      I have read about dual taxation and the principles are clear with respect to UK and Sweden who have a dual-taxation treaty.. The thumb rule is

      a> I should not be taxed(all togather) more than the maximum in both countries
      b> I should only pay social security in one place..

      The problems is my accountants do not the know the means to achieve this. They do not accept the above principles.. They are too bogged down about UK PAYE and do not want to listen to me and I do not know how to convince them.. Hence I need some advice/accountants to do this for me..

      Like for e.g I have had a salary of 100£ of which 32 is SI in Sweden and 20 is tax.. So my net income is 48..

      If we calculate the NI and tax for a net income of 48.. It will be nowhere near 32 and 20 respectively. Hence I would not need to pay anything in UK..

      But they want to treat 100 as post tax income in UK. The NI and tax will ofcourse be more if my net income is 100.. I just cannot convince them that they should not treat the tax and NI I paid in Sweden as post tax income in the UK..

      They claim this is wrong tax planning, it is blatanty incorrect accounting..

      Their get out of jail card is "we are not sweden specialists and can only talk about uk".. I am really tired of this and want someone who can understand my point of view or explain me clearly why they are doing things the way they are doing things..

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        #13
        Originally posted by avinashsa View Post
        Thanks I will give them a call.. Has anyone used them?

        I have hired accountants who have not really had the knowledge, I dont want to make the same mistake again
        They are a national Top 20 firm, you should be in safe hands. Be prepared to pay more for the expertise though.
        ContractorUK Best Forum Adviser 2013

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          #14
          Yes indeed it looks like you have a bad accountant. If your employment has already been taxed in Sweden, then you declare this as employment income from Sweden on your tax form. It would then be subject to a top-up tax, which I would imagine would be zero. Actually one option might be to talk to the tax official and explain your problem. That would be a good first step. At least you could talk through what they taxed and why. You probably need to claim that tax back. I had a similar problem in Switzerland where they taxed my interest from investments even though they'd been taxed in Germany. The tax official was very clear about why they had done it and I could quickly get to the crux of the problem. I think even just a letter to HMRC explaining that you've been taxed twice and proof would be sufficient to kick off a review. I sent in a letter to the Swiss tax authorities and they refunded my tax. It isn't difficult, you just need to explain clearly what happened.

          Of course there are a number of things which aren't clear about your case. Were you working through your Ltd or an umbrella in Sweden? If you were working through your UK Ltd I can see it would get very difficult trying to establish where it's taxed.
          Last edited by BlasterBates; 15 August 2012, 07:43.
          I'm alright Jack

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            #15
            Originally posted by avinashsa View Post
            Thanks I will give them a call.. Has anyone used them?

            I have hired accountants who have not really had the knowledge, I dont want to make the same mistake again
            I used to work for Haines Watts so can testify they do know there stuff, but as Claire says they will charge top dollar so to speak for there advice as i know the charge out rates they use! I still have a direct contact with two of the partners who work there so PM and i can give you their details.

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              #16
              You could speak to the international specialist at SJD called Tony Edwards. They don't have a section on international contracting about Sweden, although they list other countries. He is on skype as well so it won't cost you for phone calls. Or just email your questions over:

              [email protected]

              Good luck sorting this out.

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