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Global Mobility Solutions: The Tax Issues

Understand the interaction between domestic law and Double Tax Treaties to determine the correct taxation position for each individual

Global Mobility Solutions Training Course

A half-day live webinar

This course is a ‘must know’ for:
  • Payroll managers and staff
  • Business owners looking to expand overseas or bring in staff from overseas entities
  • In-house employment tax team members
  • HR experts needing knowledge of tax systems in international secondments

And a ‘nice to know’ for
  • General practitioners looking to add value to services provider to larger clients

  • The course is designed to give a practical insight into this topic rather than a theoretical analysis of the legislation.
  • It is presented by an independent advisor who has advised on transactions and solved some of the problems which have arisen.
  • Delegates will be encouraged to ask questions and clarify any issues which arise during the presentation.
  • The course will cover all current legislation and practice as well as practical issues arising from global mobility issues for payroll and HR teams.
  • We will wrap up with a case study considering various real-life aspects of the issues considered.

  • Consideration of the general tax position for inbound and outbound employees whether long-term or short-term visitors
  • To cover the specific provisions which relate to treatment of internationally mobile employees and understand the detailed conditions which enable these to apply
  • Understand the compliance issues and detailed record keeping requirements as determined by HMRC, in particular deciding who has legal responsibility for payroll taxes on the basis of employment relationships
  • Consider the specific rules relating to remuneration such as employment related securities and termination payments
  • Understand the interaction between domestic law and Double Tax Treaties to determine the correct taxation position for each individual
  • To highlight the non-tax issues which need to be considered
  • To understand the practical implications of computing tax liability where tax equalisation and other global tax policies are implemented

General considerations for internationally mobile employees

  • Residency
    • When is UK tax residency lost or acquired?
    • How are dual resident individuals treated?
    • The impact of split year treatment and the timing of relocation to avoid issues arising
    • The decisions about remote working from a legal and taxation perspective including risks of creating permanent establishment
  • Domicile
    • Potential challenges to non-domiciled status for longer term employees
    • Planning options in managing overseas assets and minimising remittances
  • Mitigation of tax liabilities for UK resident employees
    • Managing of dual contracts
    • Claiming overseas workday relief
  • Sourcing of income
    • What is taxable in the UK under general principles
      • Disregarded income for non-resident employees
      • Aspects of double tax relief including NOFTC schemes
    • Considering where duties are performed
      • Are UK duties incidental to those performed outside the UK?
    • Termination payments
      • The importance of the legal agreement between the parties
    • Employment related securities
      • Considering the nature of the share scheme, when income arises and how it is taxed
      • International mobility conditions and the interaction with remittance basis
    • Expenses deductible in computing employment income
      • Detached duty relief
      • Pension contributions

Short term business visitors

  • Understanding the legal relationships and responsibility for employment taxes
    • The payroll implications of those relationships
  • Interaction with Double Tax Treaties
    • Article 15 exemptions
      • Including considering variations to the OECD Model Treaty provisions in specific jurisdictions and the impact
      • Managing the conditions for the exemption to apply
    • The compliance aspects of managing those provisions
      • returns to be submitted to HMRC to include App 4 – 8 arrangements
      • the typical information HMRC will expect to be collated

Other relevant issues

  • Tax equalisation
    • Tax protection vs tax equalisation: the choice for employers
    • How a tax equalisation policy is determined and the factors to be taken into account
    • How this translates to practical operation of that policy including shadow payroll operation
    • The necessary compliance in the UK to implement tax equalisation
  • Social security aspects of international mobility
    • International agreements and domestic legislation
    • The key issues to consider when determining who has liability for social security and for how long
  • Checklist of other considerations for inbound and outbound employees to ensure compliance with all aspects of HR and employment legislation to ensure legal requirements to enable movement of staff are met.
  • Practical case study bringing together different aspects of the course content.

The trainer started her career with HM Inland Revenue as a Fully Trained Inspector before gaining qualification as a Chartered Tax Advisor whilst still working for the department.  She worked in Large Business Office and in the local District network covering all aspects of direct tax.

She left in 2000 to become a consultant before setting up in business providing training and consultancy.  The training involves CPD seminars, exam training, mentoring, and bespoke in-house training to all levels of accountants and tax specialists.  The consultancy involves accountants and businesses on all aspects of tax planning as well as dealing with tax disclosures, HMRC enquiries and Tribunal cases.  All aspects of direct tax and Stamp Duty Land Tax are covered.

The trainer believes that the interaction between the training and consultancy is vital to providing the highest quality service in both areas.  The consultancy allows the training to be practical by focussing on real cases where problems have been encountered and solved.  The experience of providing consultancy allows the training to be interactive with delegates encouraged to participate and discuss their own cases.

The course is designed to cover the taxation aspects of global mobility schemes with inbound and outbound employees, both short and long-term.

It will cover the technical and practical aspects of working with such staff, including a full analysis of the different legal aspects of each relationship which need to be considered in determining the correct tax treatment.  Since many aspects of the treatment rely on having a full understanding of the pattern of work, we will also be considering the practical aspects of record keeping and the paperwork needed to satisfy HMRC that the relevant treatment is correct.

The course will include detailed technical analysis of real-life client scenarios.

Number of places:

£895.00

Per participant
Discounts available for multiple place booking find out more
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