The right to work around the EU if you have Long stay residency in another EU country

[Stappy]

Hello All, This is a serious question but unfortunately it might produce a lot of Aggro. please don't


I am trying to make a chart of what hurdles ( work permits, forms, etc) an EU long stay resident has working across the EU. This is due to specialising in short 1-3 month contracts. But I am finding a lot of conflicting information.

I am a long term resident in European country (A) and am currently receiving recruitment calls about working in other European countries (Belgium and Germany).

History time - I just got an email saying I was passed for a role Belgium because a British citizen ( with a long stay permit) would need a work permit ( Belgium Gov website promise it takes <4months). A job in Switzerland also did the same last month ago because of work permit reasons ( only a few special permits for UK citizens in that Canton).

The thing is a few contractors I know based in Spain tell me that their research has produced something similar to freedom of movement. But I have spoken today to a German payroll solution and I paraphrase

"As discussed, with your permanent residency in A will I am almost certain NOT give you the right to work in Germany".

This pretty much matches most things I have found.

-BUT From the other side this website (https://service.berlin.de/dienstleistung/325475/en/
) is pretty clear a work permit is not needed.

The Spanish gov website also says something about an easy "right to work across the EU"


Has anyone got any personal experience working across the EU like this? or having this issue? My job applications are very chicken and egg right now.

Stappy

[NotAllThere]

If you have residency in a Spain, for example, you do not have a right to work in Germany. You can visit, as your residency permit is effectively a Schengen visa. Your right to work stems from citizenship, not residency.

[Stappy]

Thanks for replying NotAllThere,


But you have the right to "Residency" in a another EU country and in some ( Sweden, Hungary) countries an additional work permit is NOT needed.


So from (https://service.berlin.de/dienstleistung/325475/en/,

"Foreigners who are entitled to posses the legal status of a long-term resident in an EU member state will be granted a residence permit if their stay within the territory of the Federal Republic shall last longer than three months."


Seems this is the same for Czech, Finland and Sweden. https://en.wikipedia.org/wiki/Long-t...n)#cite_note-6


I think its complicated enough to say its complicated

Cheers

[ladymuck]

Thanks for replying NotAllThere,


But you have the right to "Residency" in a another EU country and in some ( Sweden, Hungary) countries an additional work permit is NOT needed.


So from (https://service.berlin.de/dienstleistung/325475/en/,

"Foreigners who are entitled to posses the legal status of a long-term resident in an EU member state will be granted a residence permit if their stay within the territory of the Federal Republic shall last longer than three months."


Seems this is the same for Czech, Finland and Sweden. https://en.wikipedia.org/wiki/Long-t...n)#cite_note-6


I think its complicated enough to say its complicated

Cheers

There is no blanket rule for granting the right to work across all the EU states. You have to check the rules for each country.

Your quoted sentence is about the right to live somewhere, not the right to work (which is what NAT said).

[Stappy]

Hey Lady Muck,

Seems this info is not in the wild - I will check each country then

And I agree with you both.

It seems Germany has a confusing combined work and residency permit - so having the right to residency is essentially the same thing.


Thanks, I will keep looking

[lecyclist]

It seems Germany has a confusing combined work and residency permit - so having the right to residency is essentially the same thing.


Thanks, I will keep looking

This link also suggests that permanent residency in an EU state grants you the right to work as a freelancer (Freiberufler) in Germany.

"You do not need a visa to freelance in Germany if:

• You are a citizen or a permanent resident of Germany
• You are a citizen or a permanent resident of the European Union"

https://allaboutberlin.com/guides/ho...freelance-visa

If you are working as a freelancer for a single client, this is only sustainable for short contract periods as the work category is intended for technical experts generating earnings from multiple clients (at least 18% should be from a second client, although the timeframe is not totally clear).

This is all moot of course if the agency simply chooses not to deal with British nationals to avoid unnecessary complications or delays.

[BlasterBates]

Permanent residency in one EU country doesn't give you the automatic right to work in another EU country, and you will always need to register. Unfortunately you cannot guarantee that you will be given permission, whatever the rules say on their website. It isn't the same as being an EU citizen.

[Stappy]

Hello,

Thanks for replying and yeah I'm finding they are just currently avoiding UK contractors. This is getting pretty rough, I'm pretty close to giving up my life here and going back to the UK.

Also on contracts over 3 months I had to register before Brexit anyway, like I did in the Netherlands and Hungary. Registering is not the problem.
It's not being able to work before the permit arrives and the time this might take.

Thanks ?

[RasputinDude]

I'm not sure if it helps, but I am resident in Germany was told explicitly by the German authorities that my permanent residency here (when I actually get it, my appointment is still months away) would not grant me any rights to work on other EU countries. That is the cost of my loss of EU citizenship.

[hugebrain]

I’d be interested if anyone found a good answer. I’d like too look for work in France next year (Reunion or Moorea) if it’s allowed.