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by FirmwareBurner 894 days ago
That's in every EU country for tax and social security reasons, they want you to also be a tax resident there because that dicatates your tax, labor laws and employee benefits meaning it's familiar and predictable for the company.

There's no EU wide citizenship, employee regulations and tax liability for employees but are local for each country. They don't want you earning money in one country but spemding it and taxing it in another.

This is where the EU is weaker than the US and will keep missing the mark in software.

2 comments

You pay income tax based on where you live though. So I can earn money from Germany, but if I live in Estonia, my taxes go to Estonia. Most remote workers I know are set up as LLC's, and they simply invoice their clients for the work, entirely avoiding any tax or social security issues for the employer, since you the employee have to deal with it yourself in your own country.
At first you pay taxes in the country the company you work for is registered (there might be b2b options, which might differ). Then you pay rest in the country where you have a tax residency.

In your example, at first you pay taxes in Germany and if Estonian taxes are bigger, you pay the difference there.

I am partly working for an Italian company from Germany. Billing is very simple. I invoice the Italian company according to the so-called reverse charge procedure: My invoice does not include VAT, but only the European VAT number of my and the customer's company. The customer must settle the VAT with his tax office. I only have to inform my tax office at regular intervals about the turnover with the individual companies, so that the European tax authorities can check whether the customer has declared his taxes correctly.

I invoice via my own company. But this is not mandatory. You can also apply for a VAT number as an individual and follow the same procedure. I did this before I set up the company.

This is because you run your own company. Things are different if one works for a company as an employee.
Yeah, you can but as LLCs, not as direct employees.
At least in Germany there are strict rules for what is called a pretence of self-employment. A freelancer needs to have more than one client, the client cannot set working hours, access to systems also cannot be the same as for employees etc. US has something similar AFAIK, I would expect most EU countries to have it too.
Yeah but that doesn't aid cross-EU remote work, quite the contrary.
Well yes, EU/Europe is a collection of many independent countries, unlike U.S which is one country. And you can't work in a country as an employee without having a residence permit in that country. The comparison to U.S here makes absolutely no sense.
>The comparison to U.S here makes absolutely no sense.

Why not? My ex German boss moved to the US to work for a company there and since the position is remote, he can live and work in any state he wants. You can't do that in the EU which limits labor mobility which hurts the EU economy and innovation versus the US.

United States is one country. European Union is not a country, it is a collection of many independent countries with separate laws, languages, cultures, governments. You can also live and work from any corner of the same country in EU if you want, provided that your job is also in the same country, just like in the U.S. This is not any different.

What you're saying is like can you work for a Canadian company while living in the U.S? Or an Argentinian company while living in the U.S? I don't think so. So I fail to see how U.S is somehow better here, and you're comparing European Union to 1 country, which is just ridiculous, since EU is not a country. European Union "states" are not the same as U.S states. They are actual countries.

> What you're saying is like can you work for a Canadian company while living in the U.S?

Yes, of course. You do need government approval, but generally they are willing.

However, one of the supposed goals of the EU's creation was to allow free movement of labour across member countries. Exactly so you can work in another EU country without having to secure government approval.

It is interesting that you say not only did the EU fail on that front, but that it has managed to create a situation worse than countries that have never made a formal attempt to go down that road.

I never said the EU is a country (nor does it need to be to fulfill my point), but as an economic block, if it wishes to compete with the US in terms of economy and innovation, it needs to do better in terms of labor mobility, and the current status quo is holding it back.

I hope my point of what I originally meant is clear now and you don't need to explain anymore about why the EU is not a country like the US.

There are rules to deal with this. Lots of French people near the border work in Belgium for example. They are even actively recruited.
Yeah, but those rules are in place mostly to accomodate cross border commuters. I can't easily be employed by a Belgian comapny while living and working in Portugal same as those living in Belgium, but involves extra hoops like either me working as a LLC or the company setting up an office in Portugal or hiring me through a local Porthughese third party, adn most caompnies don't want this hassle just for one employee.

I'm not in Portugal, that was just for the sake of an example.