Warning to any noobies working abroad anywhere (eg Zurich belgium amsterdam dubai )

[YHB]

<sarcasm>

Yeah - hanging around with accountants! Ooh thrilling! What fool would do that out of choice?

</sarcasm>

Take a look at your avatar... Life and soul of the party no doubt

Ive taken a look at the first two page of all your recent last posts, you have not added anything regarding giving helpful advice to anyone it seems, more a case of pointless posts aka a sad post whore..

My best mate is an accountant- Track days in a GT3 is "thrilling" trust me. Another has a Caterham for track use.

[BlasterBates]

DT18164 - DT: Switzerland: double taxation agreement, Article 15 Dependent personal services
(1) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.

(2) Notwithstanding the provisions of paragraph (1), remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:

(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.

(3) Notwithstanding the preceding provisions of this Article remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting

I rest my case

[Bear]

Take a look at your avatar... Life and soul of the party no doubt

Ive taken a look at the first two page of all your recent last posts, you have not added anything regarding giving helpful advice to anyone it seems, more a case of pointless posts aka a sad post whore..

My best mate is an accountant- Track days in a GT3 is "thrilling" trust me. Another has a Caterham for track use.

I think I've made a new friend.

[Bear]

Take a look at your avatar... Life and soul of the party no doubt

It's the boots! Everyone loves the boots!

[YHB]

lol

[YHB]

I rest my case

link??

[YHB]

I rest my case

Please unrest your case http://www.hmrc.gov.uk/manuals/dtmanual/dt18164.htm

DT18164 - DT: Switzerland: double taxation agreement, Article 15 Dependent personal services
(1) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.

This is saying you pay only in one state unless you are working in two where by the other party can also tax the part of the income made there- no mention of ONLY one country .

(2) Notwithstanding the provisions of paragraph (1), remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:

(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.

(3) Notwithstanding the preceding provisions of this Article remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting


This second part is saying under certain circumstances you may only be taxed in the first state ie the RESIDENT state ie 40%

Its all to do with RESIDENCE STATUS ie IR20

[BlasterBates]

Please unrest your case http://www.hmrc.gov.uk/manuals/dtmanual/dt18164.htm

[This is saying you pay only in one state unless you are working in two where by the other party can also tax the part of the income made there- no mention of ONLY one country .

No what this means is if some of the work/employment is attributable to the other state then this is apportioned accordingly.

i.e. if your work is only in Switzerland you only pay in Switzerland.

I was subject to this very agreement (the exact same wording is used between all EU states), I worked in Luxembourg and the UK at the same time. Part of my income was in the UK, this was taxed at UK rates. The other part of my income (work) was in Luxembourg, taxed at Luxembourg rates. I did not pay any additional tax either in Luxembourg or in the UK on the income that I received in the "contracting state". But as I've explained it was apportioned as stated in the paragraph that you are interpreting incorrectly.

My employment relationship was in Luxembourg and the UK with a single employer but two different locations.

[BrilloPad]

I think I've made a new friend.

You dont have much luck with the trolls do you!

Maybe you should tell him how big your balance sheet is

[YHB]

in that case you have not paid the tax you should have paid and owe the UK government money...

The links you are looking at are part of a whole agreement broken into bits, the part you are looking at is exactly as I have covered, If you read the whole document one by one you would come across this one (which also part of Article 18) covering "credits" ie deductions for amounts already paid and which are eligible. http://www.hmrc.gov.uk/manuals/dtmanual/DT18102.htm "Admissible for credit under the agreement " should be self explanatory.

Why would this document about credits covering income tax exist and mention "Federal and cantonal taxes on income " and "Direct federal tax " if no tax was applicable??

The UK would not go and just 'give up' its tax for the fun of it, more UK people probably contract in the UK than the other way around and the amount in questions is hundreds of thousands if not millions.

Think about it, the UK charges MORE than switzerland so has more to lose and little to gain. Its called "double tax RELIEF" manual for a reason as opposed to exemption.