What makes civil & structural engineers different from an ordinary filing?
Engineering services tied to a construction site fall under the construction permanent-establishment provision, which counts the project's duration rather than the individual engineer's days. An ordinary preparer applies the general rule and stops there, which is how the relief in the specific provision goes unclaimed.
Can you work with my existing accountant?
That is how most of these engagements run. They keep the domestic file, we take the cross-border piece, and the boundary is agreed in writing so nothing is done twice or missed.
Does a long site project create a permanent establishment abroad?
It can, and the provision that decides it is the construction one, which works differently from the general test. It measures the duration of the project itself rather than the time any individual spends there. So a team that rotates, with nobody staying long, can still take the project past the threshold, because the clock runs on the site and not on the people. The consequences fall on the employer rather than on the engineer: local registration, filing, and tax on the profit attributable to the site. Track the project's start and end dates from the outset, because the answer depends on them.
I work on site abroad but I am paid from home, so where do I pay tax?
The location of the payroll does not decide which country may tax you. Employment income is ordinarily taxable where the duties are performed, with a treaty exemption available in limited circumstances that usually fall away where the employer has a taxable presence on the site or where the stay is long enough. Engineers on a long site posting frequently fall outside that exemption while their employer carries on deducting at home only. The result is an unfiled liability in the project country and an over-deduction at home, and the two have to be corrected together rather than one at a time.
Our project overran and nobody registered locally, so what happens now?
The exposure crystallised when the project passed the threshold, not when someone noticed, so the first task is to establish the dates from the contract, the site records and the programme. From there it is a question of quantifying what is attributable to the site activity and putting the position to the project country's authority, with the outstanding registrations and returns, rather than waiting. Coming forward generally leaves more room than being found. The exercise also fixes the employees' position, which in most cases moved at the same moment as the employer's did.
Do my own days on site matter or the length of the project?
For the employer's construction permanent establishment question, the project's duration is what counts. The site is the thing being measured, so rotating staff through it does not reset anything. For your personal position, your own presence matters a great deal, because the treaty exemption for short employment abroad depends on your days, on who bears the cost of your salary, and on whether your employer has a taxable presence there. The two questions are commonly confused and often have different answers on the same project. Keep the project programme and your own travel record separately.
Why are my site allowances taxed differently from my colleagues'?
Usually because your colleagues are not on the same footing as you, even when the site and the roster are identical. Treatment of an allowance turns on the terms it is paid under, on whether it reimburses documented costs or is a flat sum, on the residency of the person receiving it, and on which country's rules apply to that person's employment. A team on one site can include home-country secondees, local hires and agency contractors, and the same payment can be handled three ways. Ask for the policy document rather than comparing pay statements, which show the result and not the reason.
Does design work done at home count towards the construction threshold?
Frequently not, and the distinction is worth keeping clean. What the construction provision measures is activity on the site itself, the building, assembly and supervision carried on there. Planning and design carried out at your own offices before anyone reaches the site is generally outside that, provided it stays genuinely separate and is contracted and invoiced as its own scope. What blurs the line is preparatory work performed at the site, or a design phase that continues alongside construction with staff attending. Record where each activity was carried out while it is happening, not afterwards.
Is "fund transfer pricing" the same thing as transfer pricing?
No — and if you came here to calculate FTP, this is not it. Fund transfer pricing is a bank's internal allocation of funding costs and benefits between its own business units, a treasury and asset-liability management discipline used to measure branch or product profitability. Tax transfer pricing is about prices between legally separate related parties across borders, and about which country taxes the resulting profit. The words overlap; the fields do not. See our transfer pricing work.
How do I actually stop being taxed twice?
In this order. Fix your residence under each country's own rules, and if both claim you, apply the treaty tie-breaker. Identify where each type of income is sourced. Read the article that covers that income type, because it decides who taxes and at what maximum rate. Then claim the relief on the residence-country return, with proof of the foreign tax. Most of the tax people lose to double taxation is lost at the last step, not the first. See how double taxation is relieved.
