The UK, right? Lots of people make the assumption that the UK is a high tax country, with a generous social safety net funded from those high taxes (some people I know would disagree with how generous – more than the US in a lot of cases, at least, but no Norway!).
I wanted to see if that’s actually a good assumption, because I’ve looked at my own situation and while my UK taxes are a bit higher than my US federal taxes, when you look at other taxes plus health care, it seemed pretty close.
Spoiler: US federal taxes are lower than UK income taxes, but when you put in typical state taxes and health insurance, it gets pretty close. Read on for more!
Background – Tax Brackets
The US and the UK both work on a marginal and progressive tax system: the percentage tax you pay on your highest dollar/pound of income is not the same as on your lowest, and the rate is higher on higher incomes. I know that’s income tax 101, but it’s really important – the first pound that you make over the 40% threshold gets taxed at 40%, but all the others are at 0% or 20%.
I started to type out the US and UK tax brackets here, and then I remembered you guys can read:
- UK Tax Brackets (there’s a hidden bracket between £100,000 and £125,000 where the personal allowance is reduced by £1 for every £2 extra earned – this results in a small but painful 60% tax bracket).
- US Federal Tax Brackets
Both countries also have some other taxes that get added on to the income taxes – National Insurance in the UK and FICA (Social Security & Medicare) in the US.
Both systems offer a variety of ways of reducing your taxable income – deductions, credits, pension contributions, etc. For most of us planning for retirement, the biggest one will be those pension contributions, although others can be significant in your particular situation (child tax credit is a big one in the US, and part of it is refundable – can be free money for Americans in the UK!).
Instead of going through a bunch of theoretical math, I thought it might be easier to illustrate in two examples. I picked two examples that aren’t in the extremes of high or low income: Average Andy, who is pretty average, and Prosperous Polly & Pat, who are at the high end of the income scale but before you start getting to really crazy money – probably roughly typical of somebody planning for FIRE. These are just illustrative, and they avoid the complications that creep in at very high and very low levels of income.
Example 1 – Average Andy
Meet Andy – he’s pretty average. He’s 30 years old and makes £40,000 or $56,000 a year, pretty close to the median salary for a full-time employee in the US or UK. He’s single, doesn’t have any income outside his job, and contributes 5% to an employer pension (without salary sacrifice) or 401(k), reducing his taxable income to £38,000 or $53,200. We’ll ignore any employer matches, since those vary tremendously by job in both countries and don’t really impact the tax calculations.
Andy’s UK Taxes
Andy’s £40,000 breaks down like this:
- Income Tax: £5,098
- National Insurance: £3,660
- Pension: £2,000 from Andy, £500 from HMRC as a tax benefit
- Take Home Pay: £29,242
In total, Andy pays the government £8,758 and gets to keep £31,742 of his total £40,500 effective pay (since HMRC tops up his pension with £500). That’s a 21.6% overall tax rate. That’s also pretty much the end of the story – there’s no state tax and he gets the NHS thrown in for “free”. There are VAT and council tax, but those are based on consumption more than income, so we’ll ignore them.
Andy’s US Taxes
Andy’s $56,000 breaks down like this:
- Federal Income Tax: $4,766
- FICA (Medicare & Social Security): $4,284
- 401(k): $2,800 from Andy – nothing directly from the IRS, but this income is deducted from his taxable income
- Preliminary Take Home Pay: $46,950
Right now, we’re at Andy having an overall 16% tax rate. But wait! Andy might still need to pay state tax. This varies all over the place, from 0% to over 10%. Let’s split the difference and call it 5% – that just happens to be the actual income tax rate in Massachusetts, after the standard deduction (actually on the lower end if you rank them all out – not so bad for Taxachusetts!)
- State Income Tax: $2,440
Now we’re at $44,510 (£31,792) – still doing better than UK Andy. But US Andy needs to pay for health insurance! This could be all over the place, depending on what (if anything) his employer offers. I found all kinds of numbers researching this post, but went with the Kaiser Family Foundation’s average employee contribution of $1,489 in 2019 for the employee part of individual health insurance.
- Health Insurance: $1,489
That doesn’t account for any deductibles or other health spending not covered by his insurance – let’s assume Andy is perfectly healthy and fortunately doesn’t have to use it. That’s good, because average annual deductibles are typically in the thousands!
That leaves US Andy a $43,021 ($30,729) take home, and overall he gets to keep $45,821 (£32,729) of his $56,000 salary, for an overall 18.2% tax + health insurance rate.
Who wins, US or UK Andy?
To me, this is a tossup. US Andy gets to keep an extra £1,063 of his hard earned cash, but if he has any health issues, that’s coming right out of his pocket, at least until he hits his deductible.
However, he’s also contributing to the rather more generous US Social Security scheme, compared to the UK State Pension (I’ll do a post on this in the future, but simple version is that the max Social Security benefit at age 66 is about $3,148 a month, State Pension at age 68 is about £759.20 a month – both of those can increase by delaying, but State Pension isn’t going to catch up).
Either way, this isn’t a clear case of “UK taxes are way higher than the US” – they’re pretty close, especially once you put state taxes and health insurance into the equation.
Example 2 – Prosperous Polly & Pat
Polly is doing well – in the top few percent of the US or UK, earning £100,000 a year ($140,000), all from her job. Her spouse, Pat, mostly stays at home with their two kids, but has a small self-employed business earning £5,000 ($7,000). Polly contributes 5% a year to her pension/401(k).
Polly & Pat’s UK Taxes
Polly & Pat file their UK taxes separately, since there’s no such thing as a joint return:
|Pension||£5,000 from Polly,|
£3,333 from HMRC
|Take Home Pay||£63,644||£5,000||£68,644|
Pat & Polly pay the government £31,356 and gets to keep £76,977 of their total £108,333 effective pay (since HMRC tops up Polly’s pension with £3,333). That’s a 28.9% overall tax rate – a chunk more than Andy’s 21.6%. As with Andy, that’s about it – no state taxes, NHS included.
Polly & Pat’s US Taxes
Polly & Pat’s US taxes get lumped together, since they’re filing jointly:
- Federal Income Tax: $12,053 (including 2 child tax credits at $2,000 each – this would change for 2021 with the recent increases to the child tax credit to $3,000 or $3,600 each, but for now it looks like that’s a COVID one-off for 2021)
- Polly’s FICA: $10,596
- Pat’s Self Employment Tax: $706 (half of this is deductible from the federal income tax, already included in the number above)
- 401(k): $7,000 from Polly
- Preliminary Take Home Pay: $116,645
So far, US Polly & Pat get to keep $123,645 of their $147,000 income, only a 15.9% tax rate compared to UK Polly & Pat at 28.9% – a big difference! But, let’s add in state tax – again assuming 5% Massachusetts flat tax:
- State Income Tax: $6,460
And, let’s not forget health insurance – because it’s for a family, the rates go up:
- Health Insurance: $5,726
And again, we’re assuming no deductibles actually get used – no emergency room visits from accidents with the kids, no health scares, etc.
Take off the state income tax and health insurance, and now we’ve got a take home of $104,459 – with the 401(k), US Polly and Pat get to keep $111,459, for an overall tax + health insurance rate of 24.2%.
Who wins, US or UK Polly & Pat?
This one is a bit further apart – in the UK, Polly & Pat are paying an effective tax rate of 28.9%, while in the US it’s only 24.2% – in the US, they get to keep more than £2,600 ($3,640) more of their hard earned money, about an extra £220 in their pocket every month.
Throw in a few medical expenses and you get pretty close, though – while the US probably comes out slightly cheaper here, I’d say that again it’s not a runaway winner.
Also, Polly’s pension/401(k) contributions are pretty low – she might be able to afford more. She probably won’t get out of the 40% band in the UK or the 22% bracket in the US, but every extra contribution makes a solid difference at those rates.
Implications for Americans in the UK
One thing these examples do reinforce is the common assumption that UK income taxes on any given bit of income are higher than US. That’s a useful simplifying assumption when thinking about your taxes, because it means, for most kinds of income, you’ll get a Foreign Tax Credit that is larger than what you owe the US, so you don’t actually owe anything.
That gets a little dicer for capital gains, dividends, and interest, since the UK has somewhat generous exemptions for these (up to £12,300, £2,000, and £1,000, respectively), where you won’t get FTCs for income that the US taxes.
On the whole, though, if you’re paying attention to how you earn and invest and making sure it’s friendly to both systems, you aren’t likely to owe Uncle Sam much, if anything. Various exceptions apply for specific situations, but it’s typically not far off!