Global Mobility Solutions: The Tax Issues

Part One

Global mobility training covers the 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: risks of creating a permanent establishment

• The effect of residency on foreign income claims

Abolition of Domicile for Tax Purposes (6 April 2025)

• Potential challenges for longer-term employees

• Planning options for managing overseas assets and minimising remittances

Foreign Income and Gains (FIG) Regime

• What it covers

• The claims

• Overseas Workday Relief

• The limitations

Comparing Assignments and Changes in Employment

• Legal issues

• Tax issues

• Social Security issues

Mitigation of Tax Liabilities for UK Resident Employees

• Managing dual contracts

• Claiming overseas workday relief

Part Two

Sourcing of Income

• This global mobility course will assess what is taxable in the UK under general principles

• Investigate disregarded income for non-resident employees

• Review aspects of Double Tax 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 (ERS)

• Considering the nature of the share scheme, when income arises and how it is taxed

• International mobility conditions and the interaction with the remittance basis

Expenses Deductible in Computing Employment Income

• Detached duty relief

• Pension contributions

Short-Term Business Visitors

• Global mobility tax training covers the legal relationships and responsibilities for employment taxes

• The payroll implications of those relationships

Interaction with Double Tax Treaties

• Article 15 exemptions

• Includes the considerations of 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 expects to be collated

National Insurance/ Social Security

• The differences between Social Security contributions and tax

• How to deal with the Social Security aspects of international assignments

• Applying for certificates of coverage

A Practical case study brings together the relevant facets of global mobility.

Training Objectives

• Global mobility training will ensure you grasp the intricacies of global mobility tax issues. This includes the tax treatment for inbound and outbound employees, whether for short-term or long-term assignments.

• Master the detailed provisions for internationally mobile employees, and the application of relevant rules to ensure compliance.

• Understand the legal and practical responsibilities surrounding payroll taxes. We explore record-keeping and employer-employee relationships as mandated by HMRC.

• Delve into the specific rules for remuneration, employment-related securities and the tax treatment of termination payments.

• Explore how domestic tax laws interact with Double Tax Treaties. Determine appropriate taxation for mobile employees.

• Recognise the non-tax considerations crucial to global mobility, such as immigration and employment law factors.

• This global mobility tax course will help you gain practical know-how in computing tax liabilities for tax equalisation and global mobility policies. You will be able to address complex scenarios with confidence.

Training Course Summary

Redcliffe’s Training's Global Mobility course offers an in-depth exploration of the tax issues related to internationally mobile employees, whether inbound or outbound, short-term or long-term.

Participants will gain the knowledge and skills of the technical, practical, and legal aspects to manage these complex relationships, the tax implications, compliance responsibilities, and record-keeping requirements as dictated by HMRC.

Global mobility tax training also addresses the significant changes introduced by BEPS reforms and how these impact global mobility taxation. Participants will become well-versed in both current and emerging global tax practices. Case studies provide real-world insights, allowing participants to analyse and solve complex global mobility scenarios with confidence.