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Comment by mathverse | Hacker News Reader

There is no Europe. It's just not a thing. European countries just work with some common framework that is better than nothing.

It's not even easy to employ people across Europe. You cant as a company in Denmark offer a normal employment contract to someone in Germany. You need a legal entity in both countries. There's also still european xenophobia and racism (ie not hiring someone because of their nationality).

Moving around in Europe sucks as well. Why should you move to country X and learn their language just because of a company/job? It makes no sense. A growing company in Berlin does not benefit anyone in Warsaw. There's no synergies.

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As a European who did precisely that (living and working in multiple different nations) and has many transnational coorperations in the industries I worked in: I don't think the disconnect is nearly as pronounced as you make it out to be.

It could be better, sure. But everything, everywhere could be better, so this is not a valid argument.

Sure as a connected landmass the EU could become more connected, especially in law and regulation. But it is becoming just that with every year.

And if you e.g. compare how easy it is for me to work in another country with another history and culture, where in the world would you have that? A Mexican coming into the US certainly has it harder than a Spaniard coming to Germany.

When I first moved from Austria to Sweden for example, I could literally use my social health care card at the doctor without any questions asked and have exit with a bill of zero SEK and a recipe for medicine for the same amount — just like I knew from home.

Interesting enough for a blogpost on it's own, I think. Have you written about this somewhere?

This is kind of obvious for most if not all EU citizens. In practice, this is just a laminated piece of paper that you have to have on you when traveling in EU. All is in regulation and cross-border cooperation between countries.

See this [1].

[1] https://en.wikipedia.org/wiki/European_Health_Insurance_Card

I studied Dutch law, so I'm well aware of all kinds of 'freedoms' we have here in Europe and the (basic) rules around them. I'm more interested in the day to day shenanigans of these things, how do they work in practice. What kind of little annoying problems does one bump into when going to a doctor here or there, for example.

It depends on the country. Different languages could be a problem, but If both countries have an agreement, is basically painless. The healthcare system in the country that provided the service will bill directly to the healthcare system where the patient has the citizenship.

In some cases tourists are required to pay a small fee for minor interventions or treatments, and the major ones are covered.

In a third group the patient will be billed in advance and then can pass the bill to his/her own healthcare system to recover the money.

> You cant as a company in Denmark offer a normal employment contract to someone in Germany. You need a legal entity in both countries.

This is the same in the US, if you hire someone in a different state you need a legal entity in that state, and there may be different local laws around taxes, health insurance, pay, etc.

> There's also still european xenophobia and racism (ie not hiring someone because of their nationality).

Same in the US.

It's true that there are a lot of different languages, but I don't understand how you get from there to "Europe isn't real". I don't really know what you mean by synergies, but EU countries can easily trade with each other and citizens can freely travel between countries, so one country's growing economy certainly benefits residents of other countries.

>This is the same in the US, if you hire someone in a different state you need a legal entity in that state, and there may be different local laws around taxes, health insurance, pay, etc.

Incorrect. You dont need a separate legal entity in each state you operate.

>It's true that there are a lot of different languages, but I don't understand how you get from there to "Europe isn't real". I don't really know what you mean by synergies, but EU countries can easily trade with each other and citizens can freely travel between countries, so one country's growing economy certainly benefits residents of other countries.

Incorrect. Those countries are still in internal competition. One country grows more at the expense of other (brain and resource drain).

> This is the same in the US, if you hire someone in a different state you need a legal entity in that state, and there may be different local laws around taxes, health insurance, pay, etc.

While you have to register your business in the other state, you most certainly don't need a separate legal entity. I help run a small company with employees in three states, but we only have a single legal entity.

Ehm this is wrong. The only true thing you stated is that someone has to learn a new language if moving. But most international companies are speaking english anyway.

Its super easy to move and change job in europe. Sign the contract and its done. The problem is each country has their own system but they are very similar. Not as easy as in the us but easy.

And there is a shitload of synergy… can you prove your point? If I look at the countries export they are mostly exporting to europe. Airbus etc are another examples.

> Its super easy to move and change job in europe. Sign the contract and its done

From what I've heard from Swedish friends that have moved to e.g Germany, it's almost impossible to setup a normal life without the help of german speaking friends. To get the pay check I need a German bank account, and then I need to fill out paper forms with tax agencies and stuff (all in German of course).

"Super easy" for me would be if I could sign a contract, move to Berlin, get an apartment, get payed to my Swedish bank account etc all without having to deal with the German government in a (to me) foreign language. Essentially that I'm a citizen where I would like to vote and have my "main presence", but that I then just can roam around EU and live/work anywhere.

But all that is not really possible, since different EU countries have wild varying tax schemes, and take different levels of responsibility for e.g health care, school, pension etc. It would be unfair for someone to pay Irish or Dutch taxes while living in Sweden and getting Swedish benefits.

I don't see any reason why a foreign bank account shouldn't work, maybe that was before SEPA-Times. But it would be very stupid because Sweden hasn't adopted the Euro yet, so they would pay double the conversion fees (when they get money from their employer it would get converted to SEK, and when they buy stuff in Berlin in card it would be converted back to EUR)

The software market shows the same issues in regards to expansion. Multilingual support? A pain. Systems? A pain. How do you consolidate the idea that it is 'easy' when market expansion shows the very opposite?

No it is not. A legal entity in Germany cannot offer a contract to someone in Poland. As a german entity you need to create a legal entity in Poland and offer a polish contract.

What synergy do you see? Because I see none.

you can work as a self employed developer etc. been there, done that, mostly its a non-issue

Sure, but that’s not employment anymore. Because you are self-employed, you are missing out on a bunch of perks. Like… notice period? What notice period?

you can create ltd and employ yourself if you want to. I have a notice period in my short term contract.

Yes, you can. But now it costs you a lot of money. Also, as someone hiring a contractor, I don’t care what arrangements you have in your own limited company. If I don’t like you, you’re out. Hopefully you have more clients.

at least in the uk running things through limited companies cost less money, not more. Again some contracts have notice periods - this goes for both sides. But yeah you dont get much protection so there is that disadvantage. I would say the biggest downside is that you dont get paid holiday (but you can simply add this to your rate) and it is harder to get mortgage.

You have a tax return to file as a private person, and as a company. I had a limited company in the UK.

No idea if the dividend tax is as low as it used to be. If it is, and you can go on through the fiscal year without claiming a salary, it sure will be cheaper. Assuming that there’s still no upper dividend limit.

you can also employ yourself and pay yourself as min salary.. that way you get some additional tax deductions..

And lose all the "european benefits"? I could work b2b from anywhere in the world at that point.

Which european benefits? Everything is local. As a greek i would lose 44% of my income annually, and have mediocre greek insurance and hospitals. What’s the benefit of this? I will sign b2b contracts with eu or us companies as long as i can.

I don't think this is quite true?

I work for a small Dutch startup, and we've employed people in Germany, Italy, and Greece without any major issues.

You obviously dont have a clue how it works. Your startup probably uses Employer of Record or PEO or B2B to employ those people.

Could you perhaps provide a link to some more information about it? Because I am reasonably sure my company uses neither, and as far as I can tell from the information provided by the Dutch government it is not a requirement either?

Employing people who live/work over the border is extremely common here, so I am having some trouble understanding how this could be done if such measurements were needed.

What does dutch government have to do with employment laws in Greece,Italy or Germany?

Labor laws are subject to national laws. If you are a cross border worker and commute from one country to another then technicall you are able to offer your country's contract.

European govermnents often have international regulations specifically to make this sort of stuff work more smoothly.

For example, a person living in Germany with German citizenship employed by a Dutch company will have to pay income taxes in The Netherlands. Similarly, they are granted social security under Dutch laws.

In some cases you fall under the employment laws of the country of residence, in other cases under those of the country of the employing company. In some cases it depends on where the work is actually done, and sometimes it even ends up being split between countries.

Fun fact: due to COVID in some cases work done in (for example) Belgium was legally considered to be work done in The Netherlands - as doing otherwise would have some nasty tax implications.

It is also not uncommon for companies to pay taxes in countries besides the one they are legally located in. For example, a webshop in Europe is required to pay sales taxes to the country and according to the laws of the country of the buyer - not the seller.

> You cant as a company in Denmark offer a normal employment contract to someone in Germany. You need a legal entity in both countries.

Are you just making stuff up in order to prove a point? Do you seriously think that companies in southern Jutland can't employ someone because they live on the other side of the border?

SIRI have actually made a digital guide for employers wishing to employ foreigners: https://www.nyidanmark.dk/da/Arbejdsgivere-og-uddannelsesste...

If you follow that guide you'll see that you can just employ a EU/EEA citizen - you only really need to do anything special if they are going to stay in Denmark for more than 90 days (which wouldn't be the case if it's a WFH deal)

The biggest hurdle is the requirement for the employee to have a NemKonto, which may be difficult and expensive (but not impossible) to find a bank that wants to setup for a foreigner, especially if they are not going to stay in Denmark.

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