Irish vs UK tax and welfare rates

[buzzy]

Hi,

I'm in an unusual situation in that i live in Ireland, where i work PAYE on a casual irregular basis and pay tax and PRSI through that, but i am also self employed in the UK, and pay tax and national insurance to the UK in that-it's also casual irregular and i can't predict when i'll be where. I have been submitting a tax return to the UK for the self employed bit which mentions the PAYE but as i have already paid tax to ireland on that, the double taxation agreement kicks in and i don't have to pay. I have also been paying full time into the UK national insurance system to cover the weeks i work and the weeks i don't because i can't predict, then more national insurance on the tax return final accounts... but i've also paying PRSI in the weeks i work PAYE in Ireland. I need to stop paying into one of the national insurance systems, but which social system is cheaper/better as i again can pretty much chose which system i pay into full time as i am in each country equally, i just want to get a refund on the weeks i've been paying double.

Also on a salary of 60k gross (combined PAYE and self emp) which tax system is better for me?

 

[John Conlon]

I cant give acomplete answer as there is more information needed re residence.
Firstly, have you an accountant/tax adviser in the UK re the self-employed element? They should have put you in order.

Anyway, I can outline as far as your info goes.

Firstly, you can't pick where to be taxed. It is based on tax law.

If you are resident and ordinarily resident here you are liable to Irish tax on world wide income with credit for foreign tax paid.

What is resident?
183 days in tax year or 280 days current and previous year.

What is ordinarily resident?
If you have been resident for 3 years you are ordinarily resident in the fourth.

What if you are not ordinarily resident?
Taxable on Irish source income and foreign income as remitted into Ireland.
This is known as the remittance basis.
This could be relevant if you dont take back all of the UK income in the year.

Domicile
Just another complication. If you are not Irish domiciled the remittance basis applies. I wont go into detail as it very complex. At its simplest are you a UK citizen?

Assume resident and ordinarily resident
Taxable here on everything
No UK tax return. I am assuming it is not a company

PRSI and National Insurance
You can only pay PRSI/NIC in one country. Your employment is here and you reside here. Therefore PRSI would be paid here.
as stated above, you would not be taxable in the UK so the NIC issue does not arise.
In any case, where someone works in several countries the default is where they reside.

As I said, a full answer requires more information.
however, you should seek professional advice in Ireland

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