Got a potentially interesting work opportunity coming up and was wondering if anyone had any real-world experience of similar.

The situation would be:
– paid and taxed in the USA
– living in France
– Working in Europe (2 established offices in central Europe plus business development activities in the UK and Europe)
– technically won’t be ‘working’ in France.
– family – wife and 5-year old – have French nationality.
– I am a British and US citizen.

Am soliciting professional advice but wondered if anyone had any experience of issues ‘cross-border commuting’ from France.

Cheers.

Holiday allowance? French or US?

I work for an American division of a global company, doing little to no work in/for the UK, but am UK based and on UK holiday entitlement etc. Wouldn’t want to be on US terms for that!

Plenty of holiday. Will be effectively president of ‘rest of the world’s outside US. Have flexibility.

Are you sure the French won’t tax you?

‘rest of the world’s outside US.

I’m “world excluding the UK”!

Good news re holiday. Should also have said, I’d imagine a fair bit of travel involved? Decent policies?

I’ve lived/worked in France before. Bureaucracy is fun, but not insurmountable. Not sure how they’d deal with you being a US employee, effectively, however.

If you’re going to be President of the RoW I’d expect to have upfront tax briefings / advice and ongoing tax return assistance from the company for the locations where you’ll be liable.
Where and how much you are taxed will depend on where your salary is being paid from, where you have ties to (property, investments, family, etc.), where you are working and for how long, and the tax treaties between the US and where you’re working.
Are you being tax equalized by the company in the US?

Thanks for all the input so far.

The tax situation is currently pending input from a specialist tax firm. Our in-house accountants are chocolate teapots when it comes to anything International.

The Fench tax law is very clear for most circumstances, yet not for my particular one. There are clear dual taxation agreements with the US and they actually have reciprocity for the social security payments too. The main quirk is that we don’t have a company as a legal entity in France. If we did, I could just be on a ‘placement’ and everything would be simple.

In general, most countries use the percentage of time spent there rule for being ‘normally resident for tax purposes’. I could possibly play the travel game and be slightly less in France, but I don’t want to risk it.

Anyhow, I’ll get that worked out. Just wondered if anyone had any experiences good or bad doing something similar.

Thanks again

This is more or less my day job, though I work with academics.

There will almost certainly be some French taxes to pay, and the social security might be payable in France – this depends on a number of factors, including where you and your family are, and how long the role is expected to last.

Be aware that the tax system in France may or may not move to PAYE in 2019, so if the advisers don’t mention that, query how they expect it to work. (They may be assuming that it won’t be introduced at all, but make them spell it out!) If they think it’s coming in in 2018, ask where they got that from, as latest information is that it has been delayed.

Being a US citizen complicates things anyway…

PM me if you have any questions.

So, looks like it’s all off. Basically a bait and switch on the whole thing by the board. We agreed to disagree and shook hands and they are working on an alternative plan. Oh well, such is life.

Cheers again for the input, STWers.