This document provides an overview of international taxation and compensation considerations for employee mobility. It discusses the importance of compliance given increased information sharing between tax and immigration authorities. The agenda includes explaining basic tax concepts, planning opportunities, and compensation considerations. It emphasizes taking an integrated approach and establishing a cross-functional team to properly manage mobility taxation and ensure legal and fiscal compliance.

1. International Taxation
and Compensation
1
Anuj Sarin
Sruthi Sagar Ananthachari
Praveen Hebbale
Pankaj Bhatia

2. Purpose of this session is to provide a
basic understanding of mobility
compliance drivers so that we can
engage/leverage the relevant internal/
external stakeholders
2

3. Agenda
1. Why?…few examples
2. Integrated mobility
3. Basic tax concepts/planning opportunities
4. Compensation/payroll considerations
5. Panel discussion
6. Q & A
3

4. Why it is important…..few examples
• Assessment to Company in
Singapore for traveler on business
trip who exceeded 60 days
(immigration sharing information)
• US/ Canada notice to Company to
produce proof of paying tax while
granting/renewing visas
• Suspension from doing business in
Australia for business traveler visa
and tax noncompliance
• Severe penalties in UK payroll audit
for not withholding on business
travelers
• Auditor request for all business
travelers to Japan during year
• Employee stopped at airport from
leaving country for not paying taxes
in Malaysia
• India PF authorities seeking
information from FRRO
4
Increased linkage b/w Tax & Immigration authorities-high
financial/business impact

5. Key functions impacting Mobility
HR/Finance/Legal
Employee tax & social security
Immigration
Compensation/ Payroll
Corp tax (Permanent
Establishment (PE) &
INTEGRATED Transfer Pricing)
MOBILITY
Significant linkage between different functions

6. Basic tax concepts
• Taxability varies from country to
country & employees may be
taxable from day 1
• Even employees on business visa
may become taxable in host location
• Even though employee may not be
taxable the host social security may
still be payable
• State/local taxes
• Withholding obligations
6
No one size fits all approach

7. Basic tax planning opportunities
• Tax Treaties
– De-minims rules
– Charge of costs
• Domestic tax regulations
– Breaking of residency
– US-Away from home regulations
– Allowance vs. Reimbursement
– Foreign Tax Credit (FTC)
• Social security/totalization
agreements
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Opportunities to reduce costs

8. Compensation/Payroll
• Assignment type/duration
• Minimum salary requirements/
Labour law compliance
• Benefits
• Industry benchmark
• Actual/ shadow payroll
• Split pay
• Imputed items
• Tax equalization
• Reimbursement of expenses?
• Documentation is key
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Legal/fiscal compliant compensation process with robust documentation

9. Final thoughts
• No ―”one fits for all” approach
• Create a cross functional team
• Identifying the owner…clear
definition of roles and
responsibilities
• Robust mobility technology tool
• Proactively identify all costs
(including hidden costs)
• Ongoing education
• Be there…..EVERYTIME
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Teamwork, ownership & accountability