Global mobility services

Some of the issues to consider

• Tax in the home jurisdiction can continue to apply
• Tax can become payable in the host jurisdiction, often under the local equivalent of the PAYE withholding system
• Employee tax filing obligations in the host jurisdiction can also arise
• There is often a mismatch between the tax treatment of relocation expenses and travel and subsistence allowances in the host country and the home country
• The social security position in both jurisdictions will have to be assessed
• Equity remuneration and share options can be particularly complex with local rules varying enormously,
• Continued participation in the company pension scheme in the home jurisdiction where tax relief is available may not be available in the host jurisdiction country as the pension scheme may not be regarded as a qualifying approved scheme in both jurisdictions
• Additional administration costs for the company
• Availability of SARP and FED relief for inbound secondees
• Permanent establishment consideration – It is important to ensure that the secondment of an individual to a foreign jurisdiction or into Ireland does not create a Permanent Establishment. If a permanent establishment is created the company may be liable to foreign tax on business profits deemed to be earned in that jurisdiction
• Corporation tax deductibility in home or host country
• VAT considerations where staff are seconded cross border

How we can help you

• Structuring remuneration packages efficiently
• Tax equalisation policies
• Home and host country tax compliance for expatriates
• Payroll services and shadow payroll services
• International social security
• International tax aspects of pensions
• Share incentive schemes for expatriates
• Personal tax planning and advisory services for individual expatriates
• Corporate tax including permanent establishment issues
• VAT and Relevant Contract Tax issues for non-resident companies

A seamless international service