Individuals working overseas may have to pay NICs in both countries after Brexit

Individuals working overseas may have to pay NICs in both countries after Brexit

Tue 15 Oct 2019

HMRC has provided guidance for UK self-employed workers relating to the situation if the UK leaves the EU with no deal. This relates to individuals working in the EU, the European Economic Area (EEA) or Switzerland.

The current rules state that workers only pay social security contributions in one country. However following a no deal, this arrangement between the UK and the EU will end. This could mean that workers may need to pay social security contributions in both countries.

The UK Government is working to make reciprocal arrangements with the EU to maintain the current position until 31 December 2020 (a transitional period).

What needs to happen now?

Self-employed workers should do the following:

  • If they are currently working in the EU, EEA or Switzerland and they have a UK-issued A1/E101 form – they will continue to pay UK NICs for the period shown on the form
  • If the end date on the form is after the date the UK leaves the EU – they need to contact the relevant non-UK authority to confirm if they need to start paying social security contributions to that country
  • If they are a UK or Irish national working in Ireland – their position will not change after the UK leaves the EU and no action is required as they are covered under the international agreement between the UK and Ireland
  • Once the UK leaves the EU, a new A1/E101 form will be issued for new applications to ensure UK NICs are paid and the NIC record is maintained.

For further advice on how individuals in business should be preparing for Brexit, please get in touch with a member of the Mazars international tax or personal tax team.