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bigduckontax
bigduckontax, Accountant
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I am a Polish student living more than 6 months/year in UK.

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I am a Polish student living more than 6 months/year in UK. Last year I worked in US for a while and also worked at my university in London (I did not work in Poland).
I paid my taxes in US and I know that, given I live more than 6 months/year in UK, I am a "tax resident" in UK.
What taxes do I have to pay in UK and what taxes in Poland? Does being "tax resident" in UK mean I don't need to pay any taxes in Poland? Do I need to prove somehow that I live in UK?
Submitted: 1 year ago.
Category: Tax
Expert:  bigduckontax replied 1 year ago.
Hello, I am Keith, one of the experts on Just Answer, and pleased to be able to help you with your question. Actually, I have already answered it, but the system has lost it! If you are resident in the UK for more than 183 days in any one tax year then you are liable to UK taxation on your world wide income. Many countries have the same rule. The UK has Double Taxation Treaties with both the States and Poland which preclude the same income stream being taxed in both jurisdictions. This is achieved by means of tax credits, the tax paid in one country being allowed as a tax credit in the other. These Treaties do not, however, protect you from differences in rates of taxation. As a citizen of an EEA state you are entitled to a personal allowance in the UK, 10.6K last tax year and 11K in the current so you may not have any liability at all. The one problem that you might have is that if you have paid too much overseas tax you cannot recover excess tax credits through the UK taxation system. I do hope that you have found my reply of assistance. Please do not hesitate to follow up on this thread if there is nnaything you do not understand.
Customer: replied 1 year ago.
Hello,
I still do not know how my "tax resident" status in UK impacts whether or not I have to pay taxes on my US income in Poland.From: "If you are resident in the UK for more than 183 days in any one tax year then you are liable to UK taxation on your world wide income. Many countries have the same rule. The UK has Double Taxation Treaties with both the States and Poland which preclude the same income stream being taxed in both jurisdictions." I understand that I just need to pay appropriate taxes in UK and that is it.
However, this "These Treaties do not, however, protect you from differences in rates of taxation." sounds as I might need to pay some taxes on my US income in Poland as well?
I am really worried that, even though I am a tax resident in UK, I will have to pay taxes on my US income (it was a very well paid job) also in Poland.
If I do have to file taxes in Poland, are all my incomes (both from jobs in US and UK) considered "UK income" and I just need to apply the Treaty between UK and Poland to all of them - as I am a tax resident in UK?
Expert:  bigduckontax replied 1 year ago.
Poland also has a Double Taxation Convention with the States along similar lines so the US tax you paid would count as a tax credit against any Polish tax due. Here is the advice regarding Polish Taxation from Your Europe: 'Live in Poland but for less than 183 days? You are not considered tax resident and pay tax only on the income earned in Poland.' You see Poland operates the same residence rule as the UK so if you are under their 183 day rule you will have no tax liability there for your US or even your UK income. As you are taxable in the UK you pay tax on your UK and US incomes, but with a tax credit for any tax deducted by the IRS.
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Expert:  bigduckontax replied 1 year ago.
Thank you for your support.