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Ask HN: How do you pay remote employees in different countries?

• kylehotchkiss 8y ago
  Transferwise Business offers an international payroll solution: https://transferwise.com/gb/business/international-payroll-via-batch-payments https://transferwise.com/gb/business/international-payroll-v... (I don't work for Transferwise, just a huge fan of their service)
  • skrebbel 8y ago
    Thanks! But I don't see much about payroll there, only about transfers. Do they also do actual payrolling? I.e. dealing with taxes, employment laws, etc etc?
    • deleted 8y ago
      [deleted]
    • rootsudo 8y ago
      No, and no company will because of the liability and fraud. They freelance, you pay them what you promise and that's it.
  • jamiepenney 8y ago
    I get paid to a bank in New Zealand via TransferWise for work I do for a company in the US. Works well, not sure of the fees on their end as they handle all of that for me. As the recipient of funds it's a nice service anyway.
  • shady-lady 8y ago
    What they do has nothing to do with payroll. They just handle cross currency transfers. Very far removed from payroll.
• rando444 8y ago
  A sole proprietorship is not a business entity. There is zero difference between a sole proprietor business and a person. I'm not sure how you got this confused, but it sounds like you need to speak to an accountant. As far as how you pay people, you just transfer them money from your bank account. All of their accounts will have SWIFT or IBAN numbers or both, and you just transfer the funds. Your accountant will take care of the rest, and they will be responsible for taxes on their end. No, they will not need to be companies, but you will need to pay them as companies, as these individuals will be responsible for their own expenses typically covered by a business (healthcare, union, taxes, etc.)
  • hapidjus 8y ago
    "There is zero difference between a sole proprietor business and a person." Are you talking about the US? As this is not the case in Sweden at least.
  • stephenr 8y ago
    This is not the case in Australia. An individual in Australia cannot issue tax invoices, but s/he can register as a sole trader and get an ABN.
  • skrebbel 8y ago
    > I'm not sure how you got this confused Mostly because it holds for zero of the countries our current team lives in. :-) I appreciate your help though, but so far accountants have been less than helpful. The ones I talked to seem to know international employment stuff worse than I do.
• dnh44 8y ago
  I would have expected that anyone looking for remote international work would have things set up to make it as easy as possible for any potential employer to be able to pay them without running into local issues.
  • DrNuke 8y ago
    Problem is employers very often just need, want and look for full-time or part-time employees, not on-call contractors. In that case, they also have to manage the legal hassle.
• tasuki 8y ago
  I've participated in similar setups before. Everyone was self-employed, working as a contractor, invoicing the German company. As we were all in the EU, this was pretty smooth. Why would you need to start a mailbox firm in every country with employees?
  • ubersoldat2k7 8y ago
    This is the easiest route. Every country has its own tax and SS laws that would be impossible to handle from a central location. Easier to pay a bit more so each contractor is able to fully pay all of these too (accountant fees included). Which is also important to take into account when negotiating salaries because 50k on Munich is not the same as on Ibiza.
  • slgeorge 8y ago
    There are two problems, employment taxes/benefits and employment rights. Lets say you have a German company and you have people working across Europe. For the sake of argument lets say that you have 15 people in France. Let say that all the people work for you 100% of the time, so they are effectively employees. On the employment taxes/benefits front how are you paying the French state those 14 peoples payroll tax, and how are you paying in for their state pension? Pragmatically, you can't do this (AFAIK) without establishing a company in the jurisdiction and registering them as employees. On the employment rights front, which jurisdictions are you following? As you have 15 people in France they are due to have a workers representative, does that fall under the French or the German system? If you have an issue with one of the team do you follow French or German employment law? Again, pragmatically each jurisdiction assumes that you fall under their employment laws and logically they'll assume you have a company in that geo.
    • tasuki 8y ago
      The 15 people in France are self-employed. They pay their own taxes to the French state, they pay their own social and health insurance. It's very simple. Wrt jurisdiction, usually the employer's jurisdiction. You don't follow "employment law", you follow "international business" law or some such, because that's what it is.
• anotheryou 8y ago
  Buffer have published their formula (and all salaries) https://open.buffer.com/salary-formula/ https://open.buffer.com/salary-formula/ it's basically: base reference salary * cost of living * role * experience edit: oh you where talking about payrole, sorry, I'm OT
• shanth 8y ago
  it's called Bitcoin.
  • duiker101 8y ago
    I would never accept payment for possible thousands of dollars in a currency that is not stable and I can't use for everyday transactions.
    • barrow-rider 8y ago
      Maybe, if the BTC payment was at a higher rate that could help offset the risk and inconvenience.
  • marfusios 8y ago
    +1, as a Freelancer I always prefer to be paid in cryptocurrencies
  • stephenr 8y ago
    I'd literally rather be paid in pancakes.
• relix 8y ago
  As far as I know, the only way to avoid creating a tax nexus in each country where you have "employees" (or contractors) is to make sure the contractors invoice you. The way this usually works is indeed the contractors have a sole proprietorship or legal entity from which they invoice you. If you just pay them without an invoice but as payroll then congratulations you're now on the hook for all taxes and social security payments in the country your now-employee works in, no matter what's in the contract. In fact you might have committed a crime against local labour law by putting in the contract that you're explicitly not liable for social security payments, benefits or business-side taxes. By not registering a mailbox firm in that country you're probably also committing some crime because this means you couldn't meet any of the local labour law obligations. This may work while everything is peachy while you pay them a higher amount which they can use to pay their social security themselves, but if your now-employee ever gets a grudge against you, they can easily file a lawsuit against you, and it'll be hard for you to defend. Your now-ex-employee will keep the inflated salary, having not paid the security benefits, and you'll be on the hook for back-paying all tax and social security payments with interest plus a fine. Especially as a startup you don't want to deal with all these administrative overheads. Just request that each person sets up a business from which they can invoice you, and that they get an accountant to help them with whatever obligations that comes with. You can suggest to pay for the accountant. It's not actually that big of a deal and will allow each person to meet the local obligations, which they (or the local accountant) will know better than you. Note that they themselves then become liable for taxes and social security payments, as someone always is.
  • slgeorge 8y ago
    This works if you have a person(s) for a period of time. But, the longer they work for you 100% of the time, and the more team members you have in a jurisdiction the more likely the team members are to be considered employees and that you have established a business in the jurisdiction. At least in the UK the separate company and 'invoice' rule is important, but there are a number of other questions used to determine if someone is an employee. As you note, the other big problem is that it places you in a very uncertain situation with labour law / labour relations.
• shweta345 8y ago
  If you need any technical writing services, feel free to email me at shweta.shetye@gmail.com. LinkedIn: https://www.linkedin.com/in/shweta-shetye-sabharwal-a669105/ https://www.linkedin.com/in/shweta-shetye-sabharwal-a669105/
• _pmf_ 8y ago
  You are asking "we're currently requiring our employees to commit tax fraud, how can we streamline this". In Germany (and a lot of other EU countries), there are laws governing bogus self-employment ("Scheinselbstständigkeit").
  • skrebbel 8y ago
    No I'm not. I'm asking "how can I pay my people". Your snark doesn't help. If you say that asking people to be contractors is tax fraud, then I ask you what the alternative is. It's an honest question, we're an honest company. Don't assume the worst.
• michaelanckaert 8y ago
  The best way to go about is ask you remote 'employees' to invoice your company. They are independent contractors and are responsible for their own taxes and social security payments. Don't think that being a contractor is hard, in some countries you can just start invoicing without any company creation or registration as long as you declare the income and pay required taxes. The downside is that anyone working as an independent contract can up and quit at moments notice. If you try to enforce exclusivity or a full time, fixed 'employment' roster some countries can sue you for fraud. The idea being that you are using contractors for full time employees and thus your company should pay employer taxes in that country.
  • paulcole 8y ago
    >The best way to go about is ask you remote 'employees' to invoice your company. They are independent contractors and are responsible for their own taxes and social security payments. This isn't legal in the Us except under specific circumstances. Whether I'm a contractor or an employee isn't my choice – the IRS has a pretty clear distinction between the two. https://www.irs.gov/newsroom/understanding-employee-vs-contractor-designation https://www.irs.gov/newsroom/understanding-employee-vs-contr...
    • lovich 8y ago
      Just send your employees all their work through an app that has a take it or leave it option on the price you'd pay them with no negotiation. Now they are all magically contractors while still acting like FTEs
      • paulcole 8y ago
        I like the way you think! Ever considered using that idea to take on the taxi industry?
• ed_balls 8y ago
  The best option is the be Sole Proprietor/company/contractor. Then they send you an invoice once a month. You can use Transfer wise, online currency exchange or your bank (bank fees tend to be high) There are other ways to hire someone, but it's a legal and paper work nightmare.
• danieltillett 8y ago
  You don't have remote employees, you have remote contractors who send you a bill for their services which you pay. They deal with their countries tax and other issues. Of course you have to treat them as real contractors and not employees. This means they chose where and when to work.
• slgeorge 8y ago
  1. Individual service companies / Sole proprietorship One thing to be aware of is that in many European companies a person who works for you full-time is considered to be an 'employee' even if they come in through an individual service company. In particular if they have no other active 'customers'. The more you treat people as 'employees' the more at risk you are: if you give them holidays, if you monitor their work closely etc, if they don't invoice you, etc. The risk is that you will have to pay employment taxes and benefits and you may be fined. Pragmatically, you are unlikely to be at risk at a low number of team members within a jurisdiction: say up to 10-15. But, at some point you will be considered to have created a permanent establishment from a tax position. 2. PE vs Limited Company Many people talk about establishing a company in a jurisdiction and then employing people etc. There's actually a state before this where you have a 'permanent establishment' from a tax position even if you don't have a limited company in the jurisdiction. You can be considered to have employees at this point and you are responsible for payroll taxes, but don't yet incur the business taxes (e.g. corporation tax). Unfortunately, it varies by European jurisdiction how likely this is. This state is essentially supposed to handle the idea of someone having an employment contract in one jurisdiction (say France), while living in another (say Germany). Practically, it doesn't work yet because the rest of the employment rights assume that you have a company in each jurisdiction. You can sort of hack it for an intermediate step. 3. Pragmatically expanding in Europe How you handle this is up to you in terms of how comfortable you are with the risk profile. The elements are too long (and boring) to go into here. In my personal opinion it makes sense to: 1. Hire team members in a limited number of jurisdictions. Basically where you believe you will eventually establish a full company: you might pick three jurisdictions you're comfortable with. 2. Handle team members as employees: this is a basic decision about how you want to handle your remote team but it has big impacts. If you treat them as 'employees' then make it clear to them that they are responsible for their employment tax, pensions, etc. 3. Risk the permanent establishment tax problem 4. When a jurisdiction gets to 10 or so people form a company. In many European countries this is around the stage where employment rights also kick in. 5. Reverse the people into the company and pay the employment taxes/benefits etc. This will cause problems because you will have to adjust pay since you will now be incurring payroll taxes and public pensions etc.
  • skrebbel 8y ago
• expertentipp 8y ago
  From my anecdotal observation, in case of EU usually a company is set up in a "permissive" country like Netherlands or Luxembourg, and the employees are implicitly required to handle the taxes and social insurances by themselves, the salary adjusted to the "cost of living" in where the employee is located.
• John_KZ 8y ago
  I don't want to sound rude, but if you don't know how this works perhaps you'd like to hire legal and accounting professional services from the country where your company is registered. HN comments won't shield you from thousands of euros in fines, double taxation, possibly tax evasion charges and other issues you really should know about before trying to manage a business.
• tixocloud 8y ago
  Thanks for posting this as I'm anticipating to be going down the same journey as well. I'm surprised that there isn't already some sort of service that handles this although it does sound like quite an administrative entanglement. Off topic: Do you get requests around embedding AI/NLP in your chat program?
  • skrebbel 8y ago
    > Off topic: Do you get requests around embedding AI/NLP in your chat program? Occasionally, but not too often. Thing is, relatively few of our customers use TalkJS for customer support - the usual suspects (Intercom, Zendesk, etc) are usually better than TalkJS for those use cases. Turns out most services that need the flexibility that TalkJS offers (eg for user-to-user chat instead of user-to-helpdesk chat) need it for direct communication between real humans. But there's a number of edge cases, so we do have a few customers who've connected TalkJS to chatbot AIs via our REST API / webhooks. There are other fields that AI could solve that we get requests about more frequently though. For instance disallowing people to share "real world" contact information such as street addresses (some of our customers are marketplaces who are afraid to lose their transaction markup if customers can easily bypass them). Given how insane street names can be this is an impossible problem, but decent AI could do better at that than any regex can. Curious why you ask!
    • tixocloud 8y ago
      I run an AI enablement company. Basically, what we do is make it easy for startups to embed AI in their apps. We can also do the actual development of the AI solution as well. Chat programs are an area of interest for us and in general, I am just curious by what people make/think about AI and how they perceive it can solve their problems. The detection of contact information is an interesting one although would not be able to solve this by just pinging the Google Maps API and then if it shows up, assume that it's an actual address at which you can discard it?
      • skrebbel 8y ago
        The problem is when people share stuff like "sure, just drop by our office on one infinite loop in cupertino". I'd have no idea how and when and what to pass to Google Maps to get an idea of which part, if any, of that message to suppress.
• barrow-rider 8y ago
  Nothing to add, just glad to hear that folks are asking this. I work remotely for a US firm and I'm baffled in their choices viz-a-viz payment sometimes.
• butternick 8y ago
  What’s the best solution if you’re a CEO but work in a different country to where your company is founded? Will the contractor model still work? N:B I’ve created a company in the UK but I’m thinking of moving to Denmark.
  • skrebbel 8y ago
    Fwiw, in the Netherlands most startup founders have a limited liability holding company to own the shares, and also use it send invoices from the holding to the startup. We don't, because being employed by our own conpany instead of sending invoices allows us to benefit from some R&D related tax cuts. But at least for Dutch law, founders sending invoices is allows and super common, maybe the same holds in the UK.
  • drsim 8y ago
    I'm the director of a UK company, now resident in Denmark. Unfortunately by moving to Denmark the company is viewed as having an office here. I therefore work for and get paid from an ApS (Danish limited company) which is wholly owned by the UK Ltd. This is called a 'datterselskab' in Danish. Look at Danløn for payroll.
• imhoguy 8y ago
  From my experience: sole proprietorship, invoices and SEPA - that is the right way to go. Some people create Limited companies. Some "employers" create one HR proxy company to group all contractors as a shield and a way to offload administrative burden from the mother company. Unfortunately EU currently has no framework for cross-border remote employees, local laws are too different to unify them all. This is not going to change soon.
• codegeek 8y ago
  You have 2 options: 1. Hire them as "freelancer/self employed" and let them invoice your company. They can either invoice as individuals or through their own company if setup. But laws get tricky depending on countries. For example, if you are an employer-based out of the US and the freelancer is NOT a US person (US person has a specific definition) , you need them to fill out something called W8-BEN form but you need to talk to a CPA/tax lawyer to determine if that's the right setup. 2. If you have more than 1 person from the same remote country, you may have to setup a subsidiary of some sort which again depends on where your business is setup and where the remote team is setup. That subsidiary can then still provide services to the parent company etc. But it then adds tons of overhead for the remote country laws, business setup and also something called "Transfer Pricing". Can get complex for smaller companies. But the advantage of this option is that you have an official local company that can pay employees on payroll, follow the local employment and tax laws etc.
  • konschubert 8y ago
    That's seems pretty convoluted. Are the any companies that can take care of these things for you?
    • konschubert 8y ago
      Apparently there is this: https://news.ycombinator.com/item?id=18170086 https://news.ycombinator.com/item?id=18170086 EDIT: I think the comment is wrong actually, trinet only offers this service for companies and employees in the US.
• fsecond722 8y ago
  I think you have to pay them through their bank accounts. If they are your employees, would you not have their bank account numbers
• em-bee 8y ago
  the european union has free movement of labor, so you should be able to just employ them just as if you would employ someone living in a different city in your own country. greetings, eMBee.
• wmboy 8y ago
  OrbitRemit works well for the countries they support, they also periodically throw in free transfers if you use them regularly enough.
• cultofmetatron 8y ago
  Been remote for a year and a half and I've taken payments in several forms including bitcoin. My preferred method when getting paid by European companies is transferwise since they let me get paid in euros and convert them to usd or whatever local currency of where I am residing. In a Pinch, I'll use paypal but its far from ideal.
• petervandijck 8y ago
  One of my startup ideas is to start a service that makes it easy to hire full-time remote employees (not contractors) and we handle all the paperwork/hassle. Anyone interested?
  • txomon 8y ago
    Europe too?
  • kdmytro 8y ago
    That would just be an outstaffing firm.