The Resource Second-guessing secondments : does your company's global mobility strategy align with your tax objectives?

Second-guessing secondments : does your company's global mobility strategy align with your tax objectives?

Label
Second-guessing secondments : does your company's global mobility strategy align with your tax objectives?
Title
Second-guessing secondments : does your company's global mobility strategy align with your tax objectives?
Creator
Subject
Language
eng
Summary
As part of the increasing globalization, company management often insists that their organization operate "seamlessly" across jurisdictions. Thus, a given individual with a specific expertise or skill set that is currently employed by a company ("Home Company") organized in one country ("Home Country") may frequently need to be transferred to work for a different company ("Host Company") in a different country ("Host Country"). This article explains why the determination of employment status may be relevant and offers some suggestions as to how to determine the manner in which the assignment relationship should be structured. Includes a table on application of local labour laws, application of local social taxes and regimes, application of benefits plans, permanent establishment, transfer pricing, Subpart F rules, and foreign tax credit rules from the Home Country and the Host Country perspective
Citation source
In: Taxes - the tax magazine. - Chicago. - Vol. 92 (2014),
http://library.link/vocab/creatorName
  • McDonald, J.D
  • Lipeles, S.R
  • Ellis, D
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • secondment
  • working abroad
  • PE
  • transfer pricing
  • Subpart F income
  • foreign tax credit
Label
Second-guessing secondments : does your company's global mobility strategy align with your tax objectives?
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Publication
Label
Second-guessing secondments : does your company's global mobility strategy align with your tax objectives?
Publication

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