Working abroad? Avoid paying double social security contributions by submitting the A1 form. A1 is an official EU form confirming that a person is still a member of the home country's social security.
A growing number of people are working across borders. Some have short assignments in, for example, Norway, Denmark and the UK. This leads to uncertainty related to which national insurance scheme they are covered by and the rights they have when working in the different countries.
The main rule
The main rule is that a person is a member of the national insurance scheme in the country he or she works, and that one should only be affiliated with the national insurance scheme in one country at a time.
This means that a foreign worker who takes up work in Norway should, as a rule, be regarded as a member of the Norwegian national insurance, and no longer be a member of the home country's national insurance scheme. This means that the employer must pay the employer's contribution on the employee's salary, and the employee must pay the social security contribution.
In Norway, the employer's contribution is 14.1% and the employee’s contribution is 8.2%.
An important exception to the main rule
An important exception to the general rule is that a person posted from his or her employer to work temporarily in another EEA country can retain the membership in the home country's national insurance scheme, without becoming a member of the working country's national insurance scheme.
Under Regulation (EC) No 883/2004 article 12, you can apply to retain national insurance membership in your home country for up to 24 months, if you have been sent to another EEA country to work. The employee cannot be sent to replace an already posted employee if the total posting period is intended to last for more than 24 months.
However article 16 opens up for member states to provide exemption from this limitation and allow the employee to retain the membership up to 5 years.
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Submit the A1 form or the E101 form
An A1 is an EU/EEA-approved form confirming that an EU / EEA citizen is a member of social security in an EU / EEA country.
The E101 form confirms that a non-EU / EEA citizen is a member of social security in an EU/EEA-member state. For example, many Indian citizens are members of the National Insurance Scheme in the UK, these are issued E101, while UK born individuals are issued A1.
It varies from country to country which application forms must be completed for the home country to issue A1.
Work in several countries for the same employer
If you work in several countries, it is your home country’s rules that determine which country's social security scheme you are covered by.
In order to maintain the social security membership in your home country, a "substantial" part of the work must be done in your home country. The European Court of Justice has stated that "substantially" means that at least 25% of the working time and / or income from work must be linked to work in the home country in order to retain the membership in the home country.
Also read: Hypotax
How to be exempt from social security in Norway?
Submit the “A1” or “E101” to the Norwegian National Insurance Authorities, NAV, which then will register that you are exempted from national insurance contributions and employer's contributions in Norway.
Also read: Norwegian National Insurance Scheme
For countries outside the EU, the question is whether Norway has a social security agreement with that specific country. If Norway has an agreement, and the employee prefers to maintain a member of the home country’s national insurance scheme, they should submit a Certificate of Coverage equivalent to A1 / E101.
Norway has bilateral social security agreements with the following countries: Australia, Bosnia and Herzegovina, Canada, Chile, France, Greece, Israel, Italy, Croatia, the Netherlands, Luxembourg, Montenegro, Portugal, Serbia, Slovenia, the United Kingdom and Northern Ireland, Switzerland, Turkey , Hungary (applies to health care), the United States and Austria, besides a separate agreement with Quebec.
The agreement with USA and Canada only covers the pension part, meaning that a US- or Canadian citizen still must pay national insurance contribution on the health part. The health contribution is 5,1 % if the employee has taxable salary income in Norway, and 6,8 % if the member has no salary income. The employer’s contribution is 7,0 %.
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Article first published December 2019, latest update August 2021.