What makes construction & contracting different from an ordinary filing?
Construction has its own permanent-establishment provision keyed to project duration, and subcontracting arrangements are aggregated in ways that surprise groups who thought each contract stood alone. 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.
When does an overseas construction site start creating tax filings?
Earlier than the point at which tax becomes payable. The treaty provision for building sites is keyed to how long the work lasts, so whether an income tax return is ultimately due is often settled looking backwards: the site either ran long enough or it did not. The calendar itself, though, starts on the day the first crew mobilises, because that is the date every later count is measured from. Registration, payroll withholding and local reporting frequently attach from the beginning of the work whether or not the duration provision is eventually met. We build the calendar from the mobilisation date and the contract programme, and mark which obligations are immediate and which are contingent on the site running long.
Does a short crew visit abroad create a foreign filing obligation?
It can, and the obligation is usually not the one people expect. The company's own exposure turns on the duration provision for building sites, which a brief visit will not reach. The workers are a separate question entirely: many countries require withholding and payroll reporting on wages for work physically performed in the country from the first day, with relief claimed afterwards rather than assumed at source. So the company may have no return to file while still owing registration and monthly payroll filings. The two questions have different tests, different deadlines and different consequences, and we answer them separately.
Do our subcontractors' months count towards our project duration?
Usually yes, and this is the point on which groups most often misjudge their position. Time spent on a site by subcontractors engaged to carry out part of the main contractor's work is generally attributed to the main contractor when the duration of the site is counted. Splitting a contract between related companies rarely resets anything either, because the provision looks at the site and the work carried on there rather than at the paperwork above it. Before assuming a site falls short, we reconstruct who was on it and on whose behalf, from site records rather than from the contract structure.
Our site overran the threshold — what do we have to file now?
The part groups miss is that once the duration provision is met, the taxing right generally runs from the start of the site rather than from the day the threshold was crossed. So the returns cover the whole period of the work, not the tail of it, and the payroll position for the earlier months usually has to be revisited as well. Late filing interest and penalties are assessed by the site country under its own rules. The work is retrospective but it is ordinary: reconstruct the period, prepare the returns, quantify what is owed, and then claim relief at home for the foreign tax once it is assessed.
Which filings come first when we open a site in another country?
In practice the order is fairly consistent. Registration with the site country comes first, because several later obligations cannot be performed without a number. Payroll withholding and its periodic returns start with the first wages for work done there. Indirect tax on the contract sits alongside that and depends on how the contract is characterised locally. The income tax return comes at the site country's year-end. The claim for relief at home comes last, because it depends on the foreign tax being determined. Getting that sequence wrong is what turns a manageable compliance file into a late one, so we set the dates out before mobilisation.
Can we claim credit at home for tax paid on a foreign site?
Generally yes, but the timing rarely lines up. The home return falls due on its own cycle while the site country's assessment may not exist yet, so relief is often claimed on a return that is later amended, or claimed a year behind. Evidence matters more here than argument: the foreign assessment, proof of payment and a clear allocation of the profit to the site are what support the claim if it is examined. We keep that evidence pack as the site runs rather than assembling it afterwards, because reconstructing the allocation once demobilisation is done is far harder.
Do I have to file in both countries?
Frequently yes, and the two filings do different jobs. The country where the income arises taxes it at source; the country where you are resident taxes your worldwide income and then gives credit for the tax already paid. Filing only one side is what leaves relief unclaimed — the credit has to be asked for on a return. We prepare both sides so the numbers agree. See dual filing.
What happens if I have not filed for several years?
Missed years are handled as one package, not one at a time, because the route chosen for the first year determines the relief available for the rest. Each country has a disclosure or relief programme with its own conditions, and entering the right one — before the authority contacts you — is usually what keeps penalties down. Filing quietly outside a programme forfeits that protection. See catching up on missed returns.
