Attached for reference is an informative Global Mobility presentation, inclusive of tax risk components.
Apart from Permanent Establishment (PE) risk, among others, I want to focus on the integration of International Tax and Global Mobility, with the following thoughts:
- Are the International Tax and Global Mobility functions aligned to address tax risks and opportunities? Are there regular meetings, information sharing and discussions of strategies, risks and opportunities?
- Are PE and related tax risks explained and discussed with Global Mobility in recurring training programs?
- Are International Tax personnel familiar with legal vs. economic employer concepts and other related mobility risks?
- Should there be dotted line and/or direct reporting structures?
- Are there red flags/alerts upon assignments/transfers of Regional/Global Sales personnel to ensure PE is not created?
- Are the legal entities to which personnel are assigned in existence?
- Should someone with international tax expertise be placed on the Global Mobility Team to minimize potential risks?
- How is Global Mobility aware of new trends, risks and opportunities, especially re: international tax?
- Is Secondment and utilization of Double Tax Treaty benefits aligned?
- How are assignments to new markets executed? Is International Tax involved in the beginning prior to execution?
- Are there specific contacts in Legal, International Tax and Global Mobility to communicate potential issues?
- Are there cross-functional training programs to highlight new issues, discuss risk gaps and Best Practices?
I welcome your ideas.