Its a late I know, and I'm sorry, I didn't see this sooner.
I don't know if you decided to continue with the role or not, but I thought a brief response was in order.
The 183 day rule is based on more than how long you are in the country for. The Double Taxation Agreement (DTA) looks to the Economic Employer.
Economic employer basically is the entity who ultimately pays for your services and / or benefits from the work. Therefore this would not be your own Ltd Co or any agency. It is the end client. If the end client has a permanent establishment in Norway (as defined in the DTA) then the 183 day rule is failed as you are receiving monies on behalf of a resident entity.
Whilst you may use your Ltd Co in Norway you would need to register as an employer there, with all of the faff that goes with that. Your salary is taxable in Norway and ultimately, so are any dividends you receive in the UK. The problems arise here because you have no protection under the DTA where you income was always taxable in Norway first. The company itself will become liable for Norwegian CT at 27%.
In addition there is social security to consider. You pay this where you work, (and it is expensive in Norway) unless you gain an A1 Certificate to continue paying your NI contributions in the UK. It is difficult (although not impossible) for a single person UK Ltd CO to obtain an A1 Certificate for its only employee and there are tests on continuing UK presence.
I realise all this may be moot now, so haven't gone into too much detail, there are further issues to consider, and happy to help if you need any further information.
Merry Christmas!
And thank you Andy
Leave a comment: