US corp. instead of UK Limited

[Neofit]

is it possible to work through my US corporation with clients in EU and in UK?

Probably the VAT handling will be different...
Work permit in EU is not a problem, have german passport

[BlasterBates]

If you intend to work in the UK or EU I would say almost certainly not. You need to be registered for tax. Doesn´t cost very much to set up a UK Ltd. In the remote possibility that you could use your US corp I think many UK accountants probably wouldn´t be able to do it simply because of the implications in the US.

I think it will be cheaper and easier to work through a UK Ltd or Umbrella.

If you intend to work in the US and just come over for an occasional visit then this would have no tax implications in the EU and you just simply tax everything in the US, and then handle this through your US accountant.

If you end up working in several countries at the same time it becomes horribly horribly complicated and you need advice in every country you work in (don´t do it).

[Wanderer]

is it possible to work through my US corporation with clients in EU and in UK?

Where would you be living? If you are in the US then yes, but if you live in the UK then you are going to have to have a company there most likely.

[Neofit]

...just come over for an occasional visit...

Will try to stick to 3-month contracts. Is is "occasional" enough?

[stek]

And what other nationality do you hold (not clear from your post but implied). I ask because Germany does not normally allow dual-citizenship* so you may have lost the other one without realising.

Also if your other citizenship is US then it's worth renouncing that to avoid the IRS' demand for tax on your World Wide income..

* Allows other EU citizenships, German parents etc but other than that...

[Neofit]

Where would you be living? If you are in the US then yes, but if you live in the UK then you are going to have to have a company there most likely.

will be in UK/EU only during contract time, I expect ~3 months

[Wanderer]

will be in UK/EU only during contract time, I expect ~3 months

Sorry but I don't think there is an easy answer.

At < 6 months in a country you may be able to avoid being tax resident but it depends very much on the country. You might want to book a chat with a professional advisor because as stek says the IRS could seek to tax you on your European income. There may be some relief available with double taxation treaties etc but it might be a bit complex.

[Neofit]

many thanks for the input!

anybody knows what happens with VAT in such case?

[stek]

many thanks for the input!

anybody knows what happens with VAT in such case?

You wouldn't charge any.

That's the least of it though, I'd imagine getting a UK or EU agent to contractually accept a US Corp to be more difficult, it's hard enough to get them to accept a legal UK LLP - seems anything that's not UK Ltd or Brolly is a risk. Within the EU it's not so bad ie I work in Ireland with my UK limited and that's been done before etc, same for most EU States but a US Corp will scare the shiite out of most dim-witted agents.

[BlasterBates]

Will try to stick to 3-month contracts. Is is "occasional" enough?

Not really. If you intend to work on contracts i.e. you are on the list of external contractors the tax authorities may decide you should be paying tax.

For me the decisive factor is if you actually get a contract, which is carried out exclusively in the country. In this case the tax authorities may expect you to register from day one. It is always going to be risky if you don´t register. You really need to register and then claim tax exemption to be sure, i.e. don´t wait for a brown envelope inviting you down to the polce station because you didn´t register.

Register and then argue you are exempt from tax. But usually for short periods you are not subject to the full rate of tax and certainly not social insurance, so it isn´t worth your while dodging tax.

If you were developing software in the US and then went to install it that would be a different matter, because you wouldn´t necessarily be paid for the time you´re there, the iincome would be for the software you developed in the US. In that case you would be pretty safe. But in the case of an agency in Holland for example ringing you up for a 3 month contract in Holland I would advise taxing that in Holland.