India–UK–EU Tax Framework 2025: What Brexit Means for NRIs

(LONDON, BERLIN, AMSTERDAM) In a year when cross-border hiring rebounds across Europe and Britain, Indian professionals and students moving between the United Kingdom and the European Union are confronting a sharper split in tax and pension rules shaped by Brexit. As 2025 assignments ramp up in finance, tech, health, and research, lawyers and employers say the core framework now hinges on India’s network of Double Taxation Avoidance Agreements and a patchwork of Social Security Agreements, with the UK operating on a separate track from Germany, France, and the Netherlands.

The immediate effect is practical and costly. Indians on temporary postings to Britain continue to pay into both India’s Employees’ Provident Fund (EPFO) and UK National Insurance, while their peers in key EU countries benefit from treaty-based detachment and pension portability.

DTAAs, SSAs and the new reality after Brexit

Treaties that once felt like background paperwork are now steering day-to-day choices.

• The India–UK DTAA, signed in 1993 and amended in 2012, still anchors how NRIs employed in Britain file taxes. It uses the credit method: income taxed in one country can be credited against tax owed in the other.
  • Salaries earned in the UK remain taxed there and, if the person is treated as non-resident in India, are not taxed again in India.
  • Capital gains on Indian shares are taxable in India, but UK residents can claim credit in their UK filings.
  • Pensions are generally taxed in the country of residence.
• What’s missing, and increasingly felt, is a bilateral Social Security Agreement (SSA) between India and the UK. Talks have stretched since 2017 and remain unresolved.
  • Consequence: Indian employees on short stints currently contribute twice—to UK National Insurance and to India’s EPFO—with no totalisation across systems.

By contrast, India’s arrangements with major EU countries are more coordinated and practical for temporary moves:

• Germany
  • DTAA: 1995, updated in 2023
  • SSA: active since 2009
• France
  • DTAA: 1992
  • SSA: 2011
• Netherlands
  • DTAA: 1989
  • SSA: 2010

These SSAs permit detachment—often up to five years (commonly cited as up to 60 months)—so Indians on temporary contracts can remain within the Indian provident fund and avoid double social-security deductions in Europe. For many, that saves an estimated 20–25% of salary that would otherwise be locked into a second pension track, and it keeps pensions payable back to India after retirement.

Critical divide: The UK is not part of any India SSA, a line that did not exist before Brexit.

What changes when professionals move across the Channel

The split is clearest when Indians switch jobs between the UK and EU:

• A software architect moving from London to Berlin, or a researcher shifting from Amsterdam to Cambridge, now toggles between two separate regimes with little carryover.
• Post-Brexit, Britain is outside EU coordination rules and isn’t covered by India’s agreements with EU states.
  • Work permits: Indian nationals apply separately for UK visas and EU schemes (e.g., German Blue Card).
  • Tax: Residence analysis must be reset each year.
  • Pensions: No totalisation between UK National Insurance and German, French, or Dutch systems.
• Result: Two annual tax returns, more documentation, and tougher proof of residence on each side.

Residency rules, certificates and practical paperwork

Residency triggers remain similar but not identical:

• India: taxes global income if a person is resident for 182 days or more in a financial year.
• UK: uses the Statutory Residence Test and a 183-day guide.
• Germany, France, Netherlands: similar 183-day thresholds combined with home-and-ties tests.

Tax credits under DTAAs limit double taxation, but only if paperwork is tight. Key documents include:

• Tax Residency Certificates (TRCs)
  • UK: HMRC’s Certificate of Residence — guidance and requests via Get a certificate of residence
  • India: residents apply using Form 10FA and receive Form 10FB; both available at:
  • Form 10FA
  • Form 10FB
  • Local EU TRCs: from German Finanzamt, French authorities, or Dutch tax office as applicable.
• Certificate of Coverage (for SSA detachment)
  • For social security detachment under India’s SSAs with Germany, France, and the Netherlands, employees typically seek a Certificate of Coverage from EPFO before departure: EPFO – International Workers/Certificate of Coverage

These forms and certificates are now routine for HR teams moving staff between London, Berlin, and Amsterdam.

Students, visiting scholars and entrepreneurs

Students and visiting scholars generally get more relief on tax, even as visa pathways tighten:

• Most India DTAAs include student and teacher clauses.
• Scholarships and research grants often remain exempt under treaty articles in both the UK and the referenced EU countries.
• Visiting professors can receive time-limited relief, commonly up to two years, in the host country.

Entrepreneurs tend to gravitate toward the Netherlands for European incorporation because of clearer rules on royalties and startup income under the DTAA—while still balancing tax on dividends and technical services tied to India.

Employer considerations and payroll planning

For employers, payroll planning has become more complex since Brexit, especially for short-term secondments:

• UK assignments still require UK National Insurance contributions, even if staff keep paying into EPFO back home. No SSA detachment exists to shield them.
• In Germany, France, and the Netherlands, detachment periods up to 60 months are possible under SSAs; pensions can remain payable to India after retirement.
• HR managers say this difference is now a deciding factor for assignment routing.
  • Analysis by VisaVerge.com indicates multinationals are reassessing whether to base India–Europe project leads in continental hubs rather than Britain when assignments are likely under five years and pension duplication could erode net pay.

Returning workers and split-career pension complexity

The contrast is stark for returning Indians with split careers across the UK and EU:

• An engineer who contributed to Germany’s DRV under detachment and then moved to Manchester may now hold two pension tracks with no bridge between them.
• France and the Netherlands allow pensions to be paid out to Indian residents.
• UK National Insurance entitlements remain ringfenced in Britain; without an India–UK SSA there’s no coordination for payments or refunds for short stays.

Industry groups estimate that workers on temporary postings could save roughly 12% in UK National Insurance if an agreement allowed detachment and totalisation.

Timing mismatches and common filing errors

Tax timing differences are a frequent source of problems:

• India’s financial year: April–March
• UK and most EU states: January–December

Impact:

• Residence test matching, foreign tax credit timing, and claiming DTAA relief become more complex.
• Common filing errors include:
  • Not using Schedule TR in India’s income-tax return (foreign tax credit disclosure).
  • Missing TRCs from each jurisdiction.
  • Late applications for Certificates of Coverage before departure.

These omissions create the double taxation and duplicate deductions the treaties aim to prevent.

Scale, sectors and geographic concentrations

The stakes are wide-ranging for Indian families and workers:

• More than 1.8 million people of Indian origin live in the UK.
• About 1.5 million live across continental Europe, concentrated in Germany, France, and the Netherlands.
• Common sectors with short cross-border stints: IT services, automotive, pharma, higher education.

Brexit has not reduced mobility but it has redrawn the rulebook. Work visas are now a separate exercise for the UK and EU, and tax and social-security relief depends on which side of the Channel a worker lands—prompting more careful assignment design and, in some cases, a preference for EU hubs because India’s SSAs with Germany, France, and the Netherlands reduce payroll friction and protect pensions.

Policy outlook and practical advice

Officials in New Delhi and London continue to discuss a possible UK SSA, but neither side has announced a timeline. Meanwhile:

• India’s bilateral approach with EU members remains the operative tool.
• There is talk of a future EU-level mobility pact that could expand mutual recognition for qualifications and perhaps make pension coordination easier, but any bloc-wide deal would sit alongside existing bilateral treaties.

Practical advice from advisers:

1. Secure TRCs promptly in every jurisdiction of residence.
2. Check residence tests early each tax year.
3. For EU postings, obtain a Certificate of Coverage from EPFO before travel so detachment applies from day one.
4. In Britain, where no detachment exists, factor double contributions into compensation and weigh whether the assignment length justifies the cost.

Key takeaway: In 2025, the post-Brexit triangle between India, the UK, and the EU is more complex but clearer on paper. The DTAA network still handles income taxes, and the SSA network in continental Europe shields many from duplicate pension deductions. The gap remains the UK: no concluded India–UK SSA. For Indians building careers across London, Berlin, and Amsterdam, that gap shows up in pay slips, pension statements, and extra forms now needed to keep cross-border life on track.