Tax

The changing global mobility landscape

The global mobility environment is changing rapidly. Businesses and their employees working internationally are faced with a complex web of regulations and laws. While tax laws change almost daily, wider political agendas and large-scale reforms have the potential to create new complexities and to increase mobility costs. Multinational businesses need to be proactive in addressing trends and their impact on global mobility.

Three issues are critical to making sure that international mobility programs and global workforces are effective in delivering growth in the future.

1. ‘Brexit’ uncertainty

The United Kingdom’s withdrawal from the European Union is set for March 2019 and will create significant changes for how multinational businesses with European operations manage the mobility of their employees between the UK and the rest of Europe.

Key to this is the removal of the current regulations regarding the free movement of people, which will mean significant changes in how businesses manage the immigration and social security position for their employees.

You need to plan and, think strategically about both formal assignments and business travellers to mitigate risk and cost exposure. You should examine the status of your employees to identify:

  • Which employees may require assistance in remaining compliant with the new immigration regulations?
  • Does your business rely on recruiting talent from Europe for your UK entity, and will the new immigration rules impact on accessing this talent?
  • Which assignment destination countries could result in higher social security costs in the future?
  • What is the cost to the business of meeting the anticipated increase in compliance administration, as well as potential dual social security costs?
  • Will the structure of your assignment packages meet the criteria of bilateral social security totalisation agreements, can they be restructured to mitigate potential cost increases?
  • Are your assignment packages robust enough to deal with the impact of changing regulations, or cope with potential volatility in exchange rates?

2. US tax reform

On 22 December 2017, the US President, Donald Trump signed tax reform into law. The enacted changes will affect how businesses view and manage international mobility in the US and will impact the costs of deploying an international workforce from the US.

Tax reform has reduced the seven income tax brackets for individuals, alongside increasing the income within each bracket. For businesses, the fall in tax rates and overall tax burden on an employee would see a hypothetical tax reduction for some assignees. This means that while an employee’s assignment tax burden remains in line with what it would have if the employee had stayed at home, the business may suffer a spike in tax costs due to higher amounts of taxable income subject to high overseas tax rates. An increase in the spread between US and foreign tax rates will ultimately mean higher tax costs that businesses will have to bear.

Businesses will need to review how their remuneration costs will change for US employees working overseas and for those moving to the US. Those pursuing an international growth strategy must consider how and where talent is deployed to make sure the return on investment is balanced.

If your grappling with the impact of US tax reform on operations when looking at employee mobility, then you should be address the following:

  • The potential impact on tax cost across an assignee population
  • Which destinations and offices offer more balanced tax cost and still achieve strategic objectives
  • Whether the right level of return on investment is still achieved where costs are increasing.

3. International business travel and BEPS

The Organisation for Economic Co-operation and Development’s Base Erosion and Profit Shifting (BEPS) Action Plan has been on the radar of multinationals for a number of years, but the new level of potential tax consequences are still only just coming into view for internationally mobile employees. In planning for the impact of BEPS, you should ask yourselves the following:

  • Does my business track the movement of our internationally mobile workforce?
  • Do we know what specific work our employees are doing overseas?
  • Do we have employees working in countries where we don’t have an established entity?

Effective mobility planning for the future

Several forces continue to shape employee mobility. Globalisation will keep moving forward, and internationally mobile workers will continue to drive growth. At the same time, countries are enacting new laws and regulations to deal with tax and shifting political agendas may create uncertainty and change that affects all areas of business and mobility.

Dynamic forward-thinking businesses need to not only keep abreast of the changing international rules but have a proactive strategy to make sure they are deploying their people effectively and cost efficiently.

To find out more about aligning a global mobility strategy with your business objectives contact one of the team.