Living Netherlands but working UK

[Qwerty1234]

I need some advice on living in the Netherlands but working in the UK. Does anybody know how the tax works? I have been told I need to pay tax in the UK over the work in and over the UK in the UK, and over all the other work I should pay tax on the Netherlands.
can anybody give me some advice? Or the name of a tax adviser in the Netherlands that is familiar with this.

And as I am here now. Does anybody where or how to sort out health care insurance? As I have been told I can not get health care insurance in the Netherlands. It is a mess!

Thanks!

[SaulGoodman]

You can get healthcare in NL. It’s through CZ and its called “verdragspolis”. Tax depends on how many days you spend in the UK. Where are you working? There are most likely more people there in the same situation that you might ask how they arrange it.

[Banana Joe]

I work in a country and live in another. My taxes and social contributions are only paid in the country where I work and healthcare coverage is provided in both countries. There are tax agreements between countries to avoid double taxation, but I guess Brexit makes things complicated.

The whole tax thing is taken care of by professionals appointed by my employer. And the pilot figure in the tax treaties I mentioned are a particular figure and it's clearly stated taxes are paid where the operator is based. My base is also in the same country so that probably makes it easier.

[lear999wa]

Pre brexit, if you paid UK NI then there wouldn't be a requirement to purchase Dutch medical insurance. However I cant say post-brexit.

[wiggy]

There were/are several in exactly that situation working for at least on UK airline so hopefully one of them might spot your post and give you a definitive answer.

In the meantime, as a starter:

As Banana Joe says the important thing is the bi-lateral tax agreement between the NL/UK..but speaking as somebody who worked UK but lived elsewhere in the EU how it can work is:

If in the UK <90 days then the UK assess you for income tax based on the proportion of your total duty time spent in the UK and UK airspace..

The country of your residence may also assess you on your global total income and tax you on that, minus the tax you've paid the uk ( but see the bi-lateral).

As I have been told I can not get health care insurance in the Netherlands. It is a mess!


If working in the UK you may well pay "National Insurance" (NI), roughly speaking equivalent to "social charges.." As lear999wa mentions pre-Brexit that would probably entitle you to healthcare in your country of residence in the EU, I have no idea where that stands at the moment. If you are already in the UK and paying NI you need to talk to the non-residents section of HMRC about now it now works and the possibility of getting coverage in the NL using a "portable healthcare document, aka an S1", which is issued by HMRC.

Apologies for all the "mights/mays", hope you get a definitive answer soon.

[Miles Magister]

Tax agreements are between national countries and are not part of the EU so are completely unaffected by Brexit

[Alrosa]

I would suggest speaking to a tax advisor - there are so many variables involved that you won’t get a definitive answer specific to your circumstances here.

You could also do some online research, and I would also suggest looking up the websites of the relevant tax authorities as a start (but I would strongly suggest a tax advisor / accountant in any case, and preferably one that is used to dealing with aircrew).

[wiggy]

Tax agreements are between national countries and are not part of the EU so are completely unaffected by Brexit

That's is of course true, it's the the provision of reciprocal reciprocal healthcare arrangements that either has or potentially is going to become more complicated.

Edit to add, for benefit of OP:

To my knowledge current contact number for UK NHS Business Service Authority with regard to querying entitlement to reciprocal healthcare, UK/NL and the possibility of obtaining an "S1/Portable Healthcare Document" is:

+44 (0)191 218 1999 (tel:+44 (0)191 218 1999)

Hope that helps, Good Luck.

[Time Traveller]

Well it's sort of true you pay tax relevant to where you are resident, but you DO still pay PAYE tax in the UK (assuming you are employed, not self employed), then via the dual taxation agreement, you offset that payment against your liabilities in NL. It's a headache, but doable DIY if you have the inclination. Some companies used to use some sort of a PAYE waiver for foreigners, but I've not heard of it receitly. NI reciprocity is a grey area I never fully understood. I believe the ehic card is still being honoured though, so make sure you have one of those.

New job, or a continuation from 2020, or two passports? I'm still seeing some UK based job ads (not necessarily aviation), which invite applicants with EU passports.

[wiggy]

Without knowing the OPs exact circumstances it's difficult to comment in detail but certainly if you're "on payroll", and paying UK Tax and NI, then establishing your actual liability to UK tax and self filing is indeed possible (there's even software to help out).

Some companies used to use some sort of a PAYE waiver for foreigners, but I've not heard of it receitly

Sounds like this: section 690 (https://www.gov.uk/government/publications/paye-apply-for-a-section-690-or-informal-treaty-direction-s690)

Basically HMRC deduct income tax at a notional rate (usually calculated based on the previous year's tax return), and then after you've filed your annual tax return showing hours you've actually worked in/out UK they either refund any overtax you've paid or bill you for any shortfall...

I believe the ehic card is still being honoured though, so make sure you have one of those.

AFAIK it is, for now, and would be a useful stop gap but caution is needed - a EHIC is only meant to be used for short stays/holidays outside the UK( though I'm well aware of what sometimes happens in reality).

If an individual becomes a non-UK resident but is UK based, paying UK NI through a UK employer then as I understand it the correct way to get long term reciprocal coverage is to register a UK issued Portable Healthcare Document S1 (https://www.gov.uk/guidance/apply-for-health-care-cover-in-the-european-economic-area-ca8454) with the authorities in the country of residence.

[FlightDetent]

I would suggest speaking to a tax advisor - there are so many variables involved that you won’t get a definitive answer specific to your circumstances here. This. Even a small variation in circumstance may lead to a different result.

In agreement with previous posters, you do not need to worry too much about where you pay the taxes - left or right. Just make sure you register and pay everywhere you should and then let the provisions of the (anti)double-taxation agreement take care of the aggregate figure. You will end up paying the higher of the calculated income tax values by the worst, but maybe not. Comparing UK to NL there will not be too much of a difference so you cannot really lose much even if the endgame is not in your favour. Unlike e.g. Canada to KSA.

N.b. it is not uncommon to be a tax resident of two countries, yet it is much less of a headache than it sounds, and it certainly does not cost you more taxes deducted. The horror stories you may have heard are usually based on the premise of someone trying unsuccessfully to escape the tax residence of their citizenship country.

[Gordomac]

Flight D : Top exhortation in your last sentence. Good advice all-round for the OP though.. Broad guide used to be quite simple when I did a stint in Holland way-back. If you spent more than 90 nights in a residence "available for your use" you were deemed "Ordinarily Resident" and subject to local Tax assessment. That is where a good Tax Accountant is worth every penny.

[Alsacienne]

Definitely seek out the help of a reputable expert. OK so you'll pay for advice, but you'll be on the right track and that advice might save you a considerable sum - as it did for me in France. A sprat to catch a mackerel comes to mind. All the very best and enjoy NL.

[SaulGoodman]

Tax agreement in Dutch;
https://www.jongbloed-fiscaaljuristen.nl/emigratie/belastingverdragen/belastingverdragen/ver._koninkrijk_2008/

if you google I am sure you can find it also in English If neccesary.


Niettegenstaande de voorgaande bepalingen van dit artikel is de beloning omschreven in het eerste lid van dit artikel verkregen door een inwoner van een Verdragsluitende Staat ter zake van een dienstbetrekking als lid van de bemanning van een schip of luchtvaartuig dat in internationaal verkeer wordt geëxploiteerd, slechts in die Staat belastbaar.




after 3 minutes. Get a good tax man. Tell him what you want as your most favorable outcome and ask him whether he can live with that. Tax agreements are not always black and white and sometimes there is a little bit of room for interpretation.

[FlightDetent]

Top exhortation in your last sentence. https://www.merriam-webster.com/dictionary/exhortation did not help :( - lost in the translation for me. Happy to apologize or clarify once the issue is understood, or we call it water under the bridge...

[stable_checked]

If in the UK <90 days then the UK assess you for income tax based on the proportion of your total duty time spent in the UK and UK airspace..

I need to do a tax return based on this for the first time. How do I do such a tax return, and how do i calculate duty spend in the uk versus duty out of U.K.?

[wiggy]

For your first UK return i'd second/third/etc a lot of the advice above about taking professional advice on what exactly you need to do and complete when dealing with UK HMRC.

When I did this many years back I used W T Fry aka "The Fry Group" for the first year but they were not cheap and you ended up doing the paperwork yourself for them to put a stamp on - others may have better recommendations.

There are spreadsheets out there such as "crewtax" that actually take the pain out of the mechanics of doing the calculations, again there are others.

[Gordomac]

FD. Sorree. Lost myself too. My intention was to applaud your closing sentence as excellent advice. I recall my Eng Lang Teacher saying " Do not let your love of the English Language run away with you".. Ignored the rotter and when I started out, couldn't even spell Pilot....now I are one......