Dan the weegie,
let's put a couple of things straight:
- there is no EU wide law on flight crew tax
- there is an EU law now about social security (you pay where you are based according to annex III of EU OPS (basically your airline must give you a base and that's where you are liable)
- there are a set of double taxation treaties between countries (there is one between each set of 2 countries and they are all very similar) and what they basically state is that you shouldn't be paying tax twice but just once, they then give you guidelines on where you should be liable to pay tax.
-LTD's and self employment are very often NOT compatible with national legislation when it comes to piloting an aircraft because it is simply a way for the AIRLINE to avoid tax and social obligations towards its workers.
-FR has always claimed that they don't have any base nor permanent estabilishment outside of Ireland and therefore they only apply the Irish rules but this scam is coming to an end and several investigations are ongoing across the EU to prove them wrong.
What should the poor pilot do then?Just join a ECA pilot association,talk to a lawyer and wait for further developments possibly without setting up dodgy things offshore or Malta.....