Cross border workers in Ireland (2023)

Introduction

The rules about cross border working on the island of Ireland have changedfor some people because Northern Ireland is nolonger part of the EU.

Irish citizens can continue to live and work in Northern Ireland and therest of the UK. British citizens can live and work in Ireland. Both Irish andUK citizens can live in Ireland and work in Northern Ireland (or live inNorthern Ireland and work in Ireland).

If you are an EEA citizen (the EU, plus Iceland, Norway and Lichtenstein)and you were living in Ireland and working in Northern Ireland before the endof 2020, you had to apply for a Frontier Worker Permit to continue working inNorthern Ireland after 1 July 2021.

If you are an EEA citizen (not Irish) who lived in Northern Ireland before31 December 2020 you had to apply for the EU SettlementScheme to continue living in Northern Ireland.

EEA citizens (not Irish) who start working in Northern Ireland for the firsttime after the end of 2020, must apply through the UK Points Based ImmigrationSystem UKpoints based immigration scheme.

What is a cross border worker?

A cross border worker (also called a ‘frontier worker’) is a person wholives in one country and works in another country, returning to the countrythey live in at least once a week.

For example, if you live in Ireland and work in Northern Ireland, you are across border worker if you return to your home in Ireland at least once aweek.

The rules covering cross border workers on the island of Ireland havechanged because Northern Ireland is no longer part of the EU.

How these new rules affect you depends on your nationality and if you werealready a cross border worker before 1 January 2021.

(Video) Cross border work

Who can live in Ireland and work in NorthernIreland?

Irish and British citizens can continue to live and work on both sides ofthe border. This is because Ireland and the UK are part of the CommonTravel Area, which gives Irish and British citizens the right to live andaccess services in both countries.

EEA and Swiss citizens

Different rules apply depending on if you were already a cross border workerbefore 1 January 2021

1. You were working in Northern Ireland and living in Ireland before 1January 2021

If you were living in Ireland and working in Northern Ireland before 1January 2021, you needed a Frontier Worker Permit tocontinue working there after 1 July 2021. There is no fee to apply for thepermit.

You can qualify for a Frontier Worker Permit if you meetall of the following:

  • You are a citizen of the EU, Switzerland, Norway, Iceland or Lichtenstein
  • You live in Ireland (or another country outside the UK)
  • You started working (including self-employment) in the UK before 1 January 2021

You must have spent less than 180 days in the UK in any 12 month period youwere working there. If you have spent more time in the UK than 180 days, youcan still qualify if you have returned to Ireland at least once every 6 months,or twice in 12 months.

You may qualify for the Permit if you stopped working in the UK butretained your worker status. You can keep your worker statusif you stopped working because:

  • You had an illness or an accident.
  • You became involuntarily unemployed. You must have registered as a jobseeker and have proof that you were looking for work in the UK while you were out of work. You can keep your worker status for:
    • 6 months if you worked in the UK for less than one year
    • As long as you were continuing to look for work, if you worked in the UK for a year or more
  • You became voluntarily unemployed and started vocational training related to the work you were doing.
  • You were pregnant or gave birth. If you are on maternity or paternity leave, you are still classed as working. If you stopped working because you had a child you can keep your worker status for up to one year. After this you can keep your worker status by registering as unemployed and looking for work.

You can read about howto apply for the Frontier Worker Permit on gov.uk.

If you are an Irish citizen, you do not need to apply for a Frontier WorkerPermit but you can choose to if you want.

2. You were not living in Ireland and working in Northern Ireland before 1January 2021

You do not qualify for the Frontier Worker Permit. If you want to work inNorthern Ireland (or another part in the UK), you should apply for permissionto work in the UK through the UKpoints based immigration scheme.

3. You live in Northern Ireland and work in Ireland

If you lived in Northern Ireland (or another part of the UK) before the endof 2020, you must apply to continue to live there through the EU SettlementScheme. You have a right to work in Ireland.

(Video) Brexit and Cross Border (“Frontier”) Workers

New residents from 1 January 2021 - If you plan to move toNorthern Ireland and work there, or to live in Northern Ireland and work inIreland, you must apply for UK residence through the PointsBased Immigration System.

Non-EEA citizens

If you are from outside the EEA, you have to get permission to live inIreland and permission to enter and work in the UK. This means you have tosatisfy both country’s immigration conditions.

Non-EEA family members

People from outside the EEA, UK and Switzerland need permission to live inIreland.

Family members of UK citizens

If your family lived with you in Ireland before 1 January 2021 and had anIRP Card with Stamp 4EU FAM (as family members of EU citizens), they wererequired to exchange their IRP Card before 30 June 2022.

Non-EEA family members of UK citizens who move to Ireland from 1 January2021 must apply for a visa or preclearance through a newimmigration scheme.

Family members of Irish citizens

If your spouse or partner is from outside the EEA, UK and Switzerland, theyhave to applyfor residence. They may also have to apply for a visato enter Ireland.

Tax

If you are living in Ireland and working in Northern Ireland, your tax andnational insurance (this is like PRSI in Ireland) is deducted from your pay.

You also have to make an annual self-assessment to Revenue in Ireland.Ireland and the UK have a double taxation agreement, which means that you willget a credit for the tax that you already paid in the UK. This makes sure thatyou won’t have to pay tax twice. But you may have to pay extra tax in Irelandbased on the difference in the tax rates between the two countries, and alsobased on the earnings of your spouse if you have one.

You should apply for TransborderWorkers’ Relief in Ireland.

(Video) Ireland residents fear border controls post-Brexit

You may be entitled to taxcredits in the UK based on how much income you have. UK tax credits is apayment made to workers on low income, and is different to tax credits inIreland, which are used to calculate how much tax you have to pay.

Social welfare

In general, the country you work in is responsible for paying social welfarepayments. For example, if you are working in Northern Ireland and your familylives in Ireland, the UK pays ChildBenefit. But if the rate of Child Benefit you get in the UK is less than ChildBenefit in Ireland, you can apply to get your payment topped up byIreland.

Irelandand the UK have agreed to continue paying social welfare to cross borderworkers and to recognise insurance contributions (national insurance or PRSI)paid in the other country, in the same way as when the UK was part of theEU.

Family benefits

Family benefits include ChildBenefit and WorkingFamily Payment in Ireland, and Child Tax Credit in the UK.

The table below explains how payments are made where one or more spouse orpartner lives in Ireland and has a spouse or partner and children inIreland.

Location of work Who pays child benefit Other possible entitlements
One person in a couple works in Northern Ireland and the other person does not work UK pays Child Benefit Means-tested Child Tax Credit in UK
One person in a couple works in Northern Ireland and the other person works in Ireland Ireland pays Child Benefit Means-tested Working Family Payment in Ireland
Both work in Northern Ireland UK pays Child Benefit Means-tested Child Tax Credit in UK

Top-up of Child Benefit in Ireland

Unemployment payments

If you are lose your job completely you claim benefits from the countrywhere you live. But if you have reduced hours or you are working casually, youapply for benefits in the country where you work.

For example, if you are made redundant from your job in Northern Ireland andyou live in Ireland, you claim Jobseeker’sBenefit or Jobseeker’sAllowance from your local INTREO office in Ireland.

If your job in Northern Ireland reduces your hours, you must apply forbenefits in Northern Ireland.

Sickness and disability

If you become sick and cannot work temporarily, your employer in NorthernIreland should pay you Statutory Sick Pay (SSP) forup to 28 weeks. If this is your only income, you can apply for SupplementaryWelfare Allowance in Ireland to top up this payment.

(Video) Protecting cross-border workers

You can claim Employment and SupportAllowance if you are unable to work due to illness or disability and yourSSP has finished or you are not entitled to SSP.

If you have to give up your job because of a sickness or disability, you maybe entitled to InvalidityPension in Ireland. This is based on your PRSI contributions and you canonly apply for it if you have worked in Ireland some time in your life. If youhave only worked in Ireland for a short period, you will only be able to get asmall amount of Invalidity Pension.

DisabilityAllowance is a payment for people who have a disability or illness thatsubstantially restricts them from doing work that would be suitable for aperson of their age, experience and qualifications. Disability Allowance ismeans tested and paid to people who are habituallyresident in Ireland.

Maternity and paternity payments and services

If you are working in Northern Ireland, you can choose to have your babythere and access healthcare services. This does not apply to you if only yourpartner (the partner who is not pregnant) works in NI.

The country you work in is responsible for your Maternity Benefit. If youare working in NI, you should apply for Statutory Maternity Paythere. If your partner is working in Northern Ireland, they can claim Paternity Pay through theiremployer. If your partner is working in Ireland they can claim paternityand parental benefits there.

Pensions

Contributions made in Northern Ireland and Ireland can be combined when youare applying for your pension. You may also be entitled to a pension from bothcountries.

If you have made contributions in both Ireland and Northern Ireland (orother parts of the UK, or other parts of the EEA) you can apply to the pensionoffice in the country where you live when you reach pension age.

Further information

More information about cross-border working and the Frontier Worker Permitis available from:

You can read about socialwelfare payment for EU citizens in Ireland.

FAQs

What is cross border working? ›

Frontier or cross border worker is a term used to describe a person who is employed in one country while living in another country.

How many border crossings are there in Ireland? ›

It is estimated that there are 300 major and minor crossings along the 499-kilometre (310 mi) border. The border is marked only by a small number of "Welcome To Northern Ireland" road signs on the UK side, placed there by the Northern Ireland Roads Service.

Can I work for a UK company and live in Ireland? ›

UK employees retain the right to live and work in Ireland without an employment or residence permit or visa under the long established Common Travel Agreement between the UK and Ireland which remains unaffected by Brexit.

Can Northern Irish work in Ireland? ›

Irish citizens can continue to live and work in Northern Ireland and the rest of the UK. British citizens can live and work in Ireland. Both Irish and UK citizens can live in Ireland and work in Northern Ireland (or live in Northern Ireland and work in Ireland).

Who pays more tax UK or Ireland? ›

“Income tax rates are broadly similar at 20% / 41% in Republic of Ireland and 20% / 40% in the UK. One significant difference is the treatment of dividend income.” Income tax is due in the state where the person is resident.

Where do cross-border workers pay taxes? ›

In most double taxation agreements the right of taxation is assigned to the state in which the work is carried out. This means that your income from non-independent work is not taxed in your country of residence, but in the country in which you carry out your work (state of work).

Can I cross the Irish border from Northern Ireland? ›

Travelling within the Common Travel Area (CTA)

There are no restrictions or testing requirements if you're travelling from one region to another within the CTA (UK, Guernsey, Jersey, Isle of Man or the Republic of Ireland). This includes travelling to Northern Ireland via the Republic of Ireland from overseas.

Is there passport control between Ireland and Northern Ireland? ›

Border control and the Common Travel Area. There are no routine passport controls in operation for Irish and UK citizens travelling between the 2 countries. However, you must show identification to board a ferry or an airplane, and some airlines and sea carriers only accept a passport as valid identification.

Why did Northern Ireland split from Ireland? ›

The conflict was caused by the disputed status of Northern Ireland within the United Kingdom and the discrimination against the Irish nationalist minority by the dominant unionist majority.

Do I pay UK tax if I work in Ireland? ›

Working in the Republic of Ireland is treated as working outside the UK for income tax purposes, therefore you will be required to prepare and submit a UK tax return each year to declare your Irish PAYE income.

Do I have to pay tax in UK and Ireland? ›

You may have to pay tax in both the UK and the other country. As such, you will probably have to look at the double taxation agreement between the two countries, if there is one (there is between the UK and Republic of Ireland).

Can I work remotely in Ireland? ›

Remote work can take place from the home, a hub, or on the move. Ireland's remote working hub infrastructure offers the chance for users to work closer to home, or while visiting another part of the country, whilst remaining within a social and collaborative office environment.

Can I move to Ireland without a job? ›

Am I eligible to move to Ireland without a job? If you are moving to Ireland as a non-EU/EEA national without a job, you must be eligible for one of the Irish immigration stamps. There are a range of immigration routes open to those who do not have a job in Ireland.

Can UK people work in Ireland? ›

UK nationals do not need a visa or residency permit to live, work or study in Ireland. Within the Common Travel Area ( CTA ), British and Irish citizens can live and work freely in each other's countries and travel freely between them. Both the UK and Irish governments are committed to protecting the CTA .

Is it easy to move to Ireland? ›

Unlike some European countries, Ireland is easy for foreigners to immigrate to, and the culture is extremely welcoming. Apart from a welcoming new home, Ireland is also sight for sore eyes.

Why Ireland is better than UK? ›

When we look at living in Ireland vs. the UK, quality of life is judged to be higher in Ireland. In fact, Ireland ranked second in the United Nations 2020 annual ranking of 189 countries, second only to Norway.

What is the average salary in Ireland? ›

The average salary in Ireland was 51,676 euros per year in 2021, compared with 51,378 in 2020. During this time period, wages in Ireland were at their lowest in 2001, when the annual wage was 37,614, and highest in the most recent year.

Is Ireland a high tax country for workers? ›

In Ireland, the average single worker faced a net average tax rate of 26.7% in 2021, compared with the OECD average of 24.6%. In other words, in Ireland the take-home pay of an average single worker, after tax and benefits, was 73.3% of their gross wage, compared with the OECD average of 75.4%.

Can you be tax resident in two countries? ›

It is possible to be resident for tax purposes in more than one country at the same time. This is known as dual residence.

Does Ireland have a double taxation treaty with UK? ›

The Double Taxation Convention entered into force on 23 December 1976 and was amended by signed protocols on 28 October 1976, 7 November 1994 and 4 November 1998. The agreement is effective in Ireland from: 1 April 1974 for Corporation Tax. 6 April 1976 for Capital Gains Tax.

Can you live in one country and pay tax in another? ›

If you are resident in two countries at the same time or are resident in a country that taxes your worldwide income, and you have income and gains from another (and that country taxes that income on the basis that it is sourced in that country) you may be liable to tax on the same income in both countries.

Can you travel from Ireland to England without a passport? ›

You do not require a passport to travel between Ireland and Great Britain, however some carriers/airlines require a passport as proof of identification, and the UK Government may require proof of citizenship (see entry requirements below).

Can you go to Northern Ireland without a passport? ›

Most people need a valid passport to enter the Republic or Northern Ireland but there are some exceptions: If you're a UK citizen, you can also use official photo identification.

Can EU citizens work in Northern Ireland after Brexit? ›

If you're an EU/EEA (non-Irish) national, you will have to have either 'settled status'(external link opens in a new window / tab) or pre-settled status or you will need to satisfy the requirements of the UK's new points-based immigration system(external link opens in a new window / tab) to work in Northern Ireland.

Can I fly from England to Northern Ireland without a passport? ›

Check your passport and travel documents before you travel

Ireland, along with the UK, is a member of the Common Travel Area. British nationals travelling from the UK don't need a passport to visit Ireland.

Can I fly to Dublin without a passport? ›

Ireland and the UK are part of the Common Travel Area (CTA), which means Irish and UK citizens can travel freely between the two countries without a passport. However, all airlines require some form of ID and most airlines do require that you have a valid passport for travel.

Is there border control between Belfast and Dublin? ›

As there is no physical border between the Republic of Ireland and Northern Ireland you will not pass through UK immigration control if arriving to Belfast through Dublin. As such, your passport will not be endorsed with a UK entry stamp.

What does 32 mean in Ireland? ›

The 32 County Sovereignty Movement, often abbreviated to 32CSM or 32csm, is an Irish republican group that was founded by Bernadette Sands McKevitt. It does not contest elections but acts as a pressure group, with branches or cumainn organised throughout the traditional counties of Ireland.

What was Ireland called before 1922? ›

Pre-1919. Following the Norman invasion, Ireland was known as Dominus Hiberniae, the Lordship of Ireland from 1171 to 1541, and the Kingdom of Ireland from 1541 to 1800. From 1801 to 1922 it was part of the United Kingdom of Great Britain and Ireland as a constituent country.

Which part of Ireland is Protestant? ›

The Protestants live throughout Ireland but they are more numerous in the counties immediately bordering Northern Ireland: Donegal, Cavan, Monaghan and Leitrim, the first three once part of Ulster.

Do Irish citizens need a national insurance number to work in the UK? ›

Do Irish Citizens need a national insurance number to work in the UK ? Yes – If you want to work in the UK you must apply for a National Insurance number. This includes people from Ireland who want to work in Northern Ireland. A UK National Insurance number is like a personal ID or account number.

How long can UK citizens stay in Ireland? ›

If you are a Non-EEA family member of a UK citizen you must register with immigration before the date shown by the stamp in your passport. You will then be given permission to stay in Ireland for an initial 12 months. This can then be renewed for 2 years, then another 3 years after that.

How many days can you work abroad without tax implications Ireland? ›

Matters start to become more complicated where a stay becomes extended, or even indefinite Employers should always bear in mind the figure of 183 days in a country in a 12-month period – this is generally the tipping point for tax residency, often together with employer obligations to operate withholding tax.

Is there a 7 year inheritance tax rule in Ireland? ›

Once seven years have elapsed between chargeable transfers an earlier transfer is no longer taken into account in determining IHT on subsequent transfers. Therefore every seven years a full nil rate band will be available to make lifetime chargeable transfers.

How long can I work outside the UK without tax implications? ›

As a rule of thumb, your risk of becoming tax resident in another country becomes significantly higher once you spend more than six months (183 days) in that country. But you could become tax resident there even if you spend less time than that.

How much money can you receive from overseas without paying taxes? ›

However, you may qualify to exclude your foreign earnings from income up to an amount that is adjusted annually for inflation ($105,900 for 2019, $107,600 for 2020, $108,700 for 2021, and $112,000 for 2022). In addition, you can exclude or deduct certain foreign housing amounts.

Do you need visa to work remotely Ireland? ›

Remote workers only need to get a digital nomad visa if they will stay longer than the time permitted with a tourist visa.

Can I be employed in Ireland and live abroad? ›

You may be going abroad to work but remain tax resident in Ireland. If so, you will be required to pay Irish tax on your total worldwide income. If you are tax resident in Ireland you are entitled to full tax credits.

Is it legal to work remotely from another country? ›

Can I Work Remotely From Another Country? It is legal to work from many countries throughout the world even if you aren't a resident of that country. However, you'll need to comply with your chosen country's visa and tax requirements in order to stay there legally.

What is a cross-border payment? ›

What are cross-border payments? Cross-border payments are financial transactions where the payer and the recipient are based in separate countries. They cover both wholesale and retail payments, including remittances.

What are cross-border commuters? ›

A cross-border commuter is someone who goes back and forth between 2 countries to work, study or do business. You are also regarded as a cross-border commuter if you live in one country and receive a benefit from the other country.

Can I work without BSN in Netherlands? ›

You are not allowed to work in the Netherlands if you do not have a Citizen Service Number (in Dutch: burgerservicenummer or BSN). Your employer uses your Citizen Service Number to pay taxes and employer's contributions on your wages.

What is a cross-border commuters Switzerland? ›

Cross-border commuters are citizens living in an EU/EFTA country but working in Switzerland (employed or self-employed with company headquarters in Switzerland). As a rule, the person must return to their place of residence (abroad) at least once a week.

What is cross border risk? ›

Cross-border risk. Describes the volatility of returns on international investments caused by events associated with a particular country as opposed to events associated solely with a particular economic or financial agent.

Why are cross border payments so expensive? ›

Cross border payments require more work from the involved credit card networks and acquiring banks as they need to convert between two different currencies. This additional workload results in extra fees that are passed down through the payment chain.

How are cross border transactions done? ›

Cross border payments take place through channels such as SWIFT, Rupee Drawing Arrangement (RDA) and Money Transfer Service Scheme (MTSS). Despite availability of conventional modes, transaction fees and excessive regulatory and documentation requirements make small-value transactions unattractive.

Can you work in one EU country and live in another? ›

If you are a citizen of the European Union (EU), you have the right to live and work in any other EU country. In general, you and your dependents cannot be refused permission to land in another EU country. You may need a valid identity card or passport.

What is G permit? ›

Cross-border commuters are foreign nationals who are resident in a foreign border zone and are gainfully employed within the neighbouring border zone of Switzerland.

Can you work in Germany and live in France? ›

With the European Union and the Schengen agreement, it is possible for french workers to work in Germany (and still living in France), and vice-versa. These workers don't need a work or a residence permit to work in Germany.

Does BSN expire? ›

After you have deregistered from a Dutch municipality, your data will be transferred to the Non-residents Records Database (RNI), which is part of the Personal Records Database (BRP). Your citizen service number (BSN) will remain valid.

Is BSN a residence permit? ›

In addition to a residence permit, you might need a citizen service number (burgerservicenummer, BSN). Generally, if you intend to stay in the Netherlands for more than 4 months, you must register with the municipality you are going to live in.

How long does it take to get a BSN Netherlands? ›

Highly skilled migrants (who made their appointment through the Expat Centre) will receive their BSN immediately after completing their appointment. New arrivals who do not have 'highly skilled migrant' status will receive their BSN after about 10 days.

How do I get a cross-border permit? ›

Applications can be submitted online or in-person at the C-BRTA offices in Eco Park, Centurion, for processing and approval. Applicants may pay for permits in cash at the C-BRTA offices, or use bank debit cards, credit cards and bank-guaranteed cheques made out to the C-BRTA.

Can I work remotely for a Swiss company? ›

A foreign or Swiss national engaged in work for a Swiss based company. Assuming the worker has a valid permit to live and work in Switzerland, under the work status “EOR” or Employer of Record, the worker can also work remotely if agreed with the client company.

Can you work in Switzerland but live in Germany? ›

you can not work in switzerland with your German permanent residency unless you have Passport issued by any EU Country.

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