As a result of Brexit, HMRC has published guidance on where social security contributions need to be paid for those who work between the UK and the EEA/Switzerland. The guidance to help both workers and employers, confirms that social security contributions only need to be paid to one country which is the country where the work usually takes place.
With the free trade agreement (FTA) that has been negotiated between the EU and the UK, mobile workers only need to pay into one country's social security system at a time. Also, according to the FTA, mobile workers can remain insured in their home country when they are temporarily working in the UK, or conversely insured in the UK when temporarily working in the EU. There are also some provisions for benefits (eg pension, sickness) which are similar to those that were in place pre-Brexit.
There are detached worker rules that need to be considered. For those who work for periods of less than two years whether this is in the country in which the work is taking place, or where they have moved from will depend on whether the country in question has adopted the rules. Detached worker rules mean that temporary workers continue to pay social security contributions to their resident country.
The detached worker rules have been adopted by the UK, so any UK worker who is sent to an EU country/Switzerland to work for up to 2 years is able to apply for an HMRC certificate and only pay National Insurance Contributions (NICs). They will not be liable to pay social contributions in the country they are working in. This rule also applies to work of up to 12 months in Iceland and 36 months in Norway.
Looking at it the other way round, if workers come to the UK to work from Norway, Switzerland, Iceland and EU countries where detached worker rules have been agreed, workers can apply for certificates and pay social security contributions to the country of their residence, rather than to the UK.
If there are no detached worker rules in place, or for those workers who do not qualify for a certificate, or are moving to a different country permanently to work, then obviously social security contributions will be due in the country where the worker is working.
HMRC guidance does point out that in Liechtenstein, UK workers who are not eligible for a certificate from HMRC will have to pay UK NIC for the first 52 weeks and may then be required to pay social security contributions in Liechtenstein.
HMRC's guidance details the eligibility criteria to apply for certificates under detached worker rules and outlines how to apply for certificates.
You can find out more here.
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