Global Mobility Solutions: The Tax Issues

The trainer is a Director of a consultancy company specialising in taxation, share scheme advice, reward and lecturing. He has developed a specialised share scheme service for small companies and advises FTSE companies on communication. The lecturing covers most aspects of Direct Taxation but his particular interests include employment taxation and transfer pricing, which poses unusual conceptual challenges.

Previous to this, he worked for Henderson for nearly 9 years, leading the Share Schemes team for part of this time.

He took the level 7 CIPD Masters qualification whilst at Henderson. Before Henderson, he was with Australia Mutual Provident (AMP) and helped set up one of the first Share Incentive Plans (SIP) for large companies in 2001. It was so unusual at the time that the Revenue phoned him up to find out how they could encourage more large companies to adopt SIP.

He started his career in taxation and for the following 16 years worked in three of the “Big Four” accountancy firms. He ended up as a Senior Manager with Deloitte & Touche, having worked on issues such as profit-related pay, share schemes, expatriate tax, tax investigations, reward management, US taxation, transfer pricing and corporate tax.

• 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 the 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 global mobility 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

• The double-tax treaties have been changed by the passing of a multilateral instrument which introduces significant changes to double-tax treaties. These include a primary purpose test as well an expanded definition of permanent establishment. The course considers these changes and the effect on the use of double-tax treaties.
• The course also looks at how HMRC and other revenue authorities obtain information on globally mobile individuals and how they use that information.
• The course is designed to give a practical insight into this topic as well as a theoretical analysis of the legislation.
• 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 tax issues for payroll and HR teams.
• We will wrap up with a case study considering various real-life aspects of the issues considered.

The course is designed to cover the taxation aspects of global mobility market 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 take into account the changes in international taxation arising from the BEPS reforms. The course will include a detailed technical analysis of a global mobility company in real-life client scenarios.