International taxation

Salary, bonuses and some equity awards can be looked at through the place the work is physically performed, the employer that pays, and whether payroll is local. A treaty may be relevant to which country has priority. Equity awards can raise a further timing question, because the grant, the vest and the sale are not always the same year.

Rental income and a later sale can create questions in the country where the property is located, and a further reporting question in the country where the owner is resident. Expenses, local property taxes and how the property is owned are local. A mortgage does not, by itself, decide the tax analysis.

The practical buying checks are on Property.

Contributions, growth inside a scheme, regular income and lump sums can be treated differently. The country that provided the pension and the country of residence may each have a question. Treaty treatment, where a treaty reaches pensions, is conceptual here: it may allocate taxing rights. It does not produce a result you can read off the existence of a treaty.

Scheme access and transfers are discussed on Pensions. Check the tax treatment before a major withdrawal or transfer.

Withholding is tax deducted by a payer — on dividends, interest, royalties, some pensions and some employment income — before you receive the balance. A treaty may reduce the rate that would otherwise apply. Any reduction usually depends on the treaty, the type of income and, often, a form or a certificate. This page does not state rates.

Where two countries have taxed the same income, relief may take the form of a credit for foreign tax, an exemption, a deduction, or a mechanism in a treaty. Which method applies, and whether it has to be claimed, depends on domestic law and on the treaty, if one is relevant.

Do not assume relief happens because tax was paid somewhere else. Evidence of the foreign tax, and the right return, are usually part of the question.

This page identifies the questions. It does not decide where tax is due. Qualified tax advice may be appropriate when income, a gain, a pension or a business touches more than one country, or when a treaty might be relevant.