Global Mobility Solutions: The Tax Issues

• 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 global mobility tax training 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.

• 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

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 work day relief

Sourcing of income

• What is taxable in the UK under general principles
• Disregarded income for non-resident employees
• Aspects of doubletax relief

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 in come 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

• Article15 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 global mobility compliance aspects of managing those provisions
• returns to be submitted to HMRC to include App4–8 arrangements
• the typical information HMRC will expect to be collated

Practical case study bringing together different aspects of the course content.

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.

The global mobility tax webinar 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 global mobility tax training 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.