Reply to: need some dual tax specialists

[sunflower]

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.

[Jeremiah@RHJAccountants]

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.

[BlasterBates]

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.

[Clare@InTouch]

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.

[avinashsa]

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..

[avinashsa]

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

[avinashsa]

Have you tried doing a the search on here?

There is a fair amount of advice given already on this

Pretty hard to give help when you haven't explained your situation/problem fully

If you need help from an accountant can I suggest you take a list from this site, ring them and ask the right questions, I'm pretty sure you will get some answers/help/point in the right direction

I am pretty new to this site and I have not found a list.. Where is the list? I only found SJD as they have an advert

[BlasterBates]

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.

[Jeremiah@RHJAccountants]

I have a tax specialist that i go to for all my international tax issues and he has helped me with tax issues from France, Belgium and Spain to name a few. So i know he can give the best advice on double taxation.

Give me a PM if you need to know more.

[The Spartan]

Hey Stek

I was using Switzerland as an example as that's where I am and I know the way it works here, to my knowledge it's the same for Sweden except I believe the tax there is meant to be 40% and if that is the case the OP will not have to pay any UK tax as they're already paying above what they would pay in the UK. According to the DTA if the OP pays more in Sweden than they would in the UK then they don't have anything to pay in UK.

[stek]

OP said Sweden, Spartan, not Switzerland.

AIUI, Sweden is nightmare tax wise, and I believe you are tax resident there from day one.

[The Spartan]

Basically as it stands if you're contract or employment abroad takes you out of the UK for a whole tax year then you are classed as not resident and do not have to pay tax in the UK, if however you're renting out property in the UK while you're working abroad you will still have to pay tax on any income you receive from the UK.

The way dual taxation works is that you get a credit on what taxes you pay in the country you're working
For Example in Switzerland the tax rate for Zurich is 8-9% therefore if I returned to the UK within a tax year I would be credited this against UK taxes meaning I would have to pay an extra:
13-14% up to 42K
31-32% on income over 42K

To bring my taxes up to UK levels, if however you work in a country where the tax rate is higher than the UK you will have nothing to pay in the UK but you will not receive any credit of taxes from the UK if you're paying more.

Basically it's always in there favour

[Clare@InTouch]

You need a specialist, rather than a general practice accountant. Try someone like these guys (Haines Watts): Haines Watts - Chartered Accountants, VAT, Business Services

[LisaContractorUmbrella]

HM Revenue & Customs: UK/Sweden Double Taxation Convention – Forms Available To Claim Relief

HTH

[Alias]

Have you tried doing a the search on here?

There is a fair amount of advice given already on this

Pretty hard to give help when you haven't explained your situation/problem fully

If you need help from an accountant can I suggest you take a list from this site, ring them and ask the right questions, I'm pretty sure you will get some answers/help/point in the right direction