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HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips
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HR seminar engineering across boundaries - Brussels 22 March 2013 - tax aspects of global mobility - Rene Philips

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  • 1. Tax Aspects ofGlobal MobilityHR Seminar Engineering Across Boundaries22 March 2013René PhilipsCarolien Van Echelpoel
  • 2. Global Mobility Assignees Getting the right people to the right place at the right Business Global Law & time to support the business Needs Mobility Regulations needs and strategy Policies© 2013 KPMG Tax & Legal Advisers civil CVBA, a member firm of the KPMG network of independent member firmsaffiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. 1All rights reserved.
  • 3. Cross-Border Personnel Moves Are Complex Actions are required in the home and host location for each of the following BUSINESS LEGAL FINANCE TAX HR UNIT • Employee • Budgeting • Corporate tax • Logistics • Compensation Contracts • Bookkeeping • Individual tax • Communication • Benefits • Intercompany • Financial • Indirect tax • Quality control • Payroll agreements Reporting • Corporate • Entry Barriers • Policies • Labor laws • Accruals structures • Administrative • Immigration • Employment • Reconciliation support laws • Charges • Facilities • Corporate law • Security© 2013 KPMG Tax & Legal Advisers civil CVBA, a member firm of the KPMG network of independent member firmsaffiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. 2All rights reserved.
  • 4. Trends Increased focus on short term business travelers Governments are becoming more aggressive in tax cases More and more anti-abuse rules are being introduced More transparency required by (tax) authorities More focus on information exchange Recent shame and blame campaigns in media© 2013 KPMG Tax & Legal Advisers civil CVBA, a member firm of the KPMG network of independent member firmsaffiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. 3All rights reserved.
  • 5. Assignment Policies & Practices - Trends Broadening Seeking Definition of Competitive “Family” Advantage Tax Equalization Keeping remains a key Assignees Save benefit Maximizing the impact of international assignments© 2013 KPMG Tax & Legal Advisers civil CVBA, a member firm of the KPMG network of independent member firmsaffiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. 4All rights reserved.
  • 6. Creating a Competitive Advantage through Forward ThinkingForward thinking is all about assessing/managing/anticipating risk • Constantly evolving laws and regulations • Expectations of business • Increasingly mobile work force • Lack of adequate tracking/administration systems • Increased scrutiny by tax, social security and immigration authorities But if done well, it can turnout to be a competitive advantage in the market place© 2013 KPMG Tax & Legal Advisers civil CVBA, a member firm of the KPMG network of independent member firmsaffiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. 5All rights reserved.
  • 7. Tax Challenges for Cross-Border Personnel Moves Unrecorded liabilities Employment Indirect Taxes Law Financial Permanent Reporting and Establishment Proxy Disclosure (PE) Exposure Payroll Related Tax Withholding Transfer Pricing and Reporting Immigration Data Privacy Compliance© 2013 KPMG Tax & Legal Advisers civil CVBA, a member firm of the KPMG network of independent member firmsaffiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. 6All rights reserved.
  • 8. It is all about anticipation and trackingOrganizations with a global workforce struggle to manage unrecorded liabilitiesassociated with:● Failure to accrue – Expatriate taxes – Pension costs – Social tax costs● Failure to track business travelers and short-term assignment lasting beyond treaty relief periods● Charging compensation costs to the host for short-term assignments© 2013 KPMG Tax & Legal Advisers civil CVBA, a member firm of the KPMG network of independent member firmsaffiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. 7All rights reserved.
  • 9. Budgeting & Assignment Approval International Assignment Process Objectives Risk Process Assignment Cost Estimate • Ensure cost is budgeted, cost • Violation of corporate tax is minimized and corporate/ policies and procedures individual tax issues are • Exposure of corporate entity addressed to law in a jurisdiction where a business entity has not be • Ensure polices are followed established • Tax issues for both the • Ensure approval for company (PE) and the assignment cost and which employee division will bear cost • Exposure to tax penalties and interest • Establish accrual for • Unexpected cost due to non- assignment costs compliance • Legal issues • Bad publicity/reputational damage© 2013 KPMG Tax & Legal Advisers civil CVBA, a member firm of the KPMG network of independent member firmsaffiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. 8All rights reserved.
  • 10. Immigration International Assignment Process Objectives Risk Process Immigration • Ensure application with • Employee begins working local government to legally in country prior to work in country obtaining work permit. Family begins residency • Ensure application of before obtaining proper family (non-working) to authorization reside in country legally • Bad press and possible ban to establish business • Imprisonment or ban from ever working/entering in country • Tax costs are higher than expected due to incorrect work permit • Immigration costs are higher than expected© 2013 KPMG Tax & Legal Advisers civil CVBA, a member firm of the KPMG network of independent member firmsaffiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. 9All rights reserved.
  • 11. Immigration• Common pattern but requirements differ from country to country• The length of the trip, the scope of the activities and the personal situation of the assignee are decisive for the type of document• Do not rely on what may seemed like the quick solutions in the past• Process is often longer than expected – medical examination often required – authenticated public documents, translated in local languages – accompanying family members• Authorities are more actively enforcing prohibitions against unlawful employment - important to obey the spirit as well as the letter of the law PLANNING AHEAD© 2013 KPMG Tax & Legal Advisers civil CVBA, a member firm of the KPMG network of independent member firmsaffiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. 10All rights reserved.
  • 12. Thank youRené PhilipsGlobal Head of International Executive Servicesrphilips1@kpmg.com+32 2 708 3807Carolien Van EchelpoelExecutive Managercvanechelpoel@kpmg.com+32 2 708 4796
  • 13. © 2013, KPMG Tax & Legal Advisers civil CVBA, amember firm of the KPMG network of independentmember firms affiliated with KPMG InternationalCooperative (KPMG International), a Swiss entity. Allrights reservedThe KPMG name, logo and ‘cutting through complexity’are registered trademarks or trademarks of KPMGInternational Cooperative (KPMG International)

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