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As an EU citizen and within the EU, is it possible to remotely work in one country and pay taxes in another?

My particular case would be:

  • Employed, registered and paying taxes in Ireland
  • Living in France
  • In your example, it seems that you want to work in and pay taxes to the Netherlands, while only living in Ireland. The rest of the question seems like the requirements should instead cover working and paying taxes in different countries, without specifying where you live in relation to either. Can you clarify the situation of which countries are involved and which of them are desired for work/residence/taxes? – Kamil Drakari Sep 11 '18 at 19:33
  • @KamilDrakari edited my question clarifying my situation – Abel Alejandro Sep 12 '18 at 7:53
  • There are usually three relevant factors for taxes. Place of work, place of residence, and nationality. When only your place of work is in another country, you might be able to pay taxes only locally. Are you Irish or French? Note this is not standardized in the EU yet, and it may involve reclaiming taxes paid abroad. – MSalters Sep 12 '18 at 9:19
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Well, in the situation you described, both countries will want you to pay taxes:

  • Ireland, because your main source of income is in Ireland (employed by an Irish company);
  • France, because your place of residence is in France, and because, as you work remotely, they consider that your main source of income is in France as well.

There are complex rules that try to make sure this doesn't happen and you only pay taxes in one of the two countries, but those can make your lawyer(s) rich.

Here's the convention on this topic between France and Ireland (french version). Don't read it too quickly, you may sometimes think "oh this is my case", only to find an exception on the next page, and the definitions can be quite complex.

In addition, there are also social security/national insurance charges, as well as work regulations which differ substantially, and France especially will be keen on having you pay your share in France, not in Ireland (unless you want to go to Ireland any time you need to see a doctor...).

See for instance the cases of airlines like Ryanair: they try all they can to make sure their staff is considered to be under Irish rules (for taxes, social security, regulations...), but France does not quite agree, and Ryanair was found guilty (in french). And that's for people who are not even always in France.

In your case, if you work "remotely", you are effectively working in France as well as living in France, so you should be employed under french law, pay french social security and french taxes. There's no going around that. You can try otherwise, but they'll catch up (even when you are legitimately working abroad they can be quite annoying).

If it weren't the case, all companies in France would already have set up a subsidiary in Ireland to employ all French employees who would be "working remotely".

If you want to pay taxes in Ireland, the solution is simple: move there.

  • The essence of the answer is correct. You pay taxes where you are a resident. That being said there exist double tax treaties(complex rules mentioned in the 1st paragraph) between most countries ( and definitely within the EU) for such situations to avoid being double taxed. – Leon Dec 12 '18 at 15:05
  • To be clear the 'double-tax treaties' don't say "since you are paying taxes elsewhere you wont' pay them here" they say 'we will count the taxes you pay elsewhere against the ones you have to pay here". So you can end up paying taxes to two countries, just not twice as much. – DJClayworth Dec 12 '18 at 17:01
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In your case i doubt it, you pay taxes where you life. Where you life is decided, by the amount of days you were in the country in this years.

It is quite common in my region, to life in france and work in germany and vice versa since i live in a border region - but in your case i doubt you won't achieve this in longterm. If you start working in ireland now, you would most likely pay your taxes in france this year assuming you was there the first 9 month of this year. But you must report this to both countrys, then you get back your automatic paid taxes in ireland and pay your tax debt in france.

Edit: You work remotly out of france, and only your employer is in ireland-> you should pay taxes in france. Sorry i am bad in reading.

  • 1
    In the general case, it's actually a bit more complex, because you can be taxed not only where you live, but also where your main source of income is. It ends up in lots of exceptions going one way or the other for dozens of pages in bilateral treaties. – jcaron Dec 12 '18 at 13:49
  • Except remote work is not "source of income where you pretend to be working" - it is "income is generated where you WORK" - and that is where you sit down on your ass in front of the computer. – TomTom Dec 12 '18 at 15:26

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