Irish citizen working in Scotland for US Company - tax implications and company car benefit in kind
Hey all! I've got a bit of a complicated situation and could really use some tax advice. I'm an Irish citizen currently living in Dublin, and I've just received a job offer from a tech company based in Seattle, USA. The job requires me to relocate to Edinburgh, Scotland for at least 7 months each year starting in March. I understand that as an Irish citizen I have the right to live and work in Scotland without any visa issues, so that part is sorted. I'll be a full-time employee for this American company (they're headquartered in Washington state), and they're providing me with a company car while I'm based in Scotland. My main concerns are: 1. Will I end up paying US taxes on my income? If so, what kind of percentages am I looking at? 2. How does the "benefit in kind" work for the company car in this situation? 3. What questions should I be asking the HR department before I accept this offer? This is my first time dealing with international tax stuff, so any advice would be massively appreciated! Thanks in advance!
19 comments


Harper Thompson
This is definitely a complex tax situation crossing three countries! Let me help break this down: First, as an Irish citizen working in Scotland for a US company, your tax situation will depend on several factors including your tax residency status in each country. Generally speaking, the US taxes its citizens and permanent residents on worldwide income, but for non-US citizens working abroad for US companies, you typically wouldn't pay US taxes if you're physically performing the work outside the US. Instead, you'd likely be subject to UK taxation while working in Scotland. For the company car, the "benefit in kind" would be handled under UK tax rules, not US rules, since you're physically using the car in Scotland. The UK has specific formulas for calculating company car tax based on the car's value, CO2 emissions, and fuel type. Some key questions to ask your employer: - Will they be setting you up on UK payroll or US payroll? - Are they offering any tax equalization benefits? - Will they provide tax preparation assistance for potentially filing in multiple countries? - Have they worked with the UK's PAYE system before?
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Lucas Bey
•Thank you so much for this detailed response! It makes more sense now. One follow-up question - if I'm on US payroll but physically working in Scotland, would the US company still withhold US taxes from my paycheck, and then I'd have to file for a refund? Or should they not be withholding US taxes at all? Also, do you know if there's a tax treaty between Ireland, the UK and the US that might help prevent double taxation?
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Harper Thompson
•If you're on US payroll but physically working in Scotland, the company should ideally not withhold US income taxes since you're not performing services in the US. However, some US companies aren't familiar with these rules and might withhold anyway. If that happens, you would indeed need to file a US tax return to claim a refund of those withheld taxes. Yes, there are tax treaties between all three countries: US-UK, US-Ireland, and UK-Ireland. These treaties have provisions to prevent double taxation, typically through foreign tax credits or exemptions. For example, if you end up paying taxes to the UK on your income, you might be able to claim those as a credit against any potential Irish tax liability if you maintain tax residency in Ireland.
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Caleb Stark
After going through something similar (American working remotely for a UK company while living in Spain), I found this amazing tool that saved me so much stress. Check out https://taxr.ai - they specialize in analyzing international tax situations and documents. I uploaded my offer letter and some basic info about my citizenship and residence situation, and they gave me a detailed breakdown of my tax obligations in each country. Honestly made things so much clearer than the conflicting advice I was getting from friends. They specifically helped me understand how the tax treaties worked between countries and what forms I needed to file. They also provided a personalized checklist of questions to ask my employer and documents I should request. Worth checking out before you make any decisions!
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Jade O'Malley
•How accurate was their analysis compared to what actually happened with your taxes? I'm in a somewhat similar situation (Canadian working for a German company while living in Portugal) and getting reliable info has been a nightmare.
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Hunter Edmunds
•I'm pretty skeptical of these online tax tools for international situations. Did they actually understand the nuances of the Spanish tax system? I've found that most of these tools are very US-focused and miss a lot of the European considerations.
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Caleb Stark
•Their analysis was spot-on for my situation. The tax calculations they projected ended up being within about €300 of what I actually paid, which I thought was impressive given all the variables. The biggest value was having everything explained in plain language instead of tax jargon. Regarding European considerations, they actually seemed very knowledgeable about EU tax systems. They flagged several Spain-specific deductions I was eligible for that even my local accountant missed initially. They also explained how Brexit had changed certain aspects of UK-EU taxation that applied to my situation. I was initially skeptical too but was genuinely impressed with their international coverage.
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Jade O'Malley
Just wanted to update after using taxr.ai that the previous commenter recommended. It was seriously helpful for my complicated international tax situation. I uploaded my employment contract and answered some questions about my Irish citizenship and Scottish residence plans. The report they generated clearly showed I won't owe US taxes as long as I don't spend more than 30 days physically working in the US each year. They also provided estimates of my UK tax liability and explained how the UK-Ireland tax treaty would prevent double taxation on the same income. For the company car, they even calculated the approximate benefit in kind tax I'll pay in the UK based on the car details I provided. Ended up being about £320/month in additional taxable benefit which was higher than I expected but good to know in advance. Most helpful was the pre-written email template they provided with all the questions I should ask my employer's HR department. Made me look way more informed than I actually am!
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Ella Lewis
If you're dealing with any tax-related questions for the IRS, I highly recommend using Claimyr (https://claimyr.com). I was stuck in an international tax nightmare with the IRS about foreign earned income exclusion and couldn't get through to anyone on the phone for weeks. Claimyr got me connected to an actual IRS agent in under 20 minutes when I'd been trying for days with no luck. You can see how it works here: https://youtu.be/_kiP6q8DX5c Even though most of your tax situation will be UK-based, you'll likely still need to interface with the IRS at some point regarding your employment with a US company. Having a direct line to speak with them saved me hours of frustration and conflicting information.
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Andrew Pinnock
•How does this actually work? Do they just have some special phone number for the IRS that regular people don't have access to?
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Brianna Schmidt
•This sounds like a scam. Nobody gets through to the IRS that quickly, especially for international tax questions. I bet they just put you in the same queue everyone else waits in and charge you for the privilege.
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Ella Lewis
•It's not a special phone number - they use technology that navigates the IRS phone system and waits in the queue for you. When they reach a human agent, you get a call back. It's basically like having someone wait on hold for you, which is especially helpful with international calls that can get expensive. They have partnerships with several government agencies, not just the IRS. It's definitely not a scam - you only pay if they actually connect you with an agent. I was skeptical too until I tried it. The technology basically automates the hold time process so you don't have to wait yourself. For international tax issues, it's particularly useful since calling the IRS from abroad can be complicated and expensive.
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Brianna Schmidt
I need to eat my words and apologize to the person who recommended Claimyr. After my skeptical comment, I decided to try it myself for an international tax question about my contractor income from US companies. I was connected to an IRS international tax specialist in about 15 minutes when I had previously spent HOURS trying to get through. The agent was able to clarify exactly which forms I needed for my situation and confirmed I was eligible for a treaty benefit I wasn't sure about. The service actually works exactly as described. They don't put you at the front of any queue (which would be a scam), they just handle the waiting and navigating of the phone system for you. For anyone dealing with cross-border taxation, especially with the US involved, it's genuinely worth it. Never been so happy to be wrong!
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Alexis Renard
Something nobody has mentioned yet - make sure you understand if you'll be staying tax resident in Ireland or becoming tax resident in the UK. This has massive implications! In the UK, you're typically considered tax resident if you spend 183+ days there in a tax year. Since you mentioned being in Scotland for 7 months (~210 days), you'd likely become UK tax resident. However, Ireland has its own residency tests too, so you could potentially be considered tax resident in both countries. This is where the Ireland-UK tax treaty comes in to determine which country has primary taxing rights. Also, keep in mind that the UK and US tax years are different! UK tax year runs April 6 - April 5, while US is calendar year. Makes things even more complicated when you're trying to calculate time spent in each place.
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Camila Jordan
•Adding to this excellent point - Scotland has some slightly different tax rates than the rest of the UK! Not a massive difference, but the tax bands and rates in Scotland aren't exactly the same as England/Wales.
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Lucas Bey
•That's a really important point I hadn't considered. So even though I'd be working for a US company, I could end up being a UK tax resident because of the 183+ days rule. Do you know if there's any way to maintain Irish tax residency instead, since that's where my permanent home would still be?
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Alexis Renard
•You could potentially maintain Irish tax residency by ensuring you spend enough time in Ireland and limiting your time in Scotland to under 183 days per UK tax year. Ireland has a similar 183-day rule, but also considers other factors like maintaining a permanent home there. One approach some people use is careful day counting across tax years - for example, spending just under 183 days in the UK in each UK tax year, but timing it so those days fall across two different Irish tax years. This requires very careful planning and documentation of your whereabouts. Keep in mind though that if you're physically performing the work in Scotland, the UK will have taxing rights on that income regardless of your residency status. The difference is that as a UK resident, they tax your worldwide income, while as a non-resident, they only tax UK-source income.
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Tyler Lefleur
Don't forget about social security/national insurance contributions! This is completely separate from income tax and follows different rules. The US has "totalization agreements" with both the UK and Ireland that determine where you pay social security. Generally, if you're temporarily posted to the UK (less than 5 years), you might be able to remain in the US social security system rather than paying UK National Insurance. But since you're not a US citizen, different rules might apply. This is something your employer should definitely help sort out, as getting it wrong can mean either double-paying into two systems or having gaps in your social security coverage.
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Madeline Blaze
•Really good point about social security! When I moved from Ireland to the UK for work, I was able to get a form from the Irish authorities confirming I was still covered under the Irish system, which meant I didn't have to pay UK National Insurance. I believe it was called Form E101 or something similar. Worth looking into!
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