Global mobility

Specialist tax and corporate finance advice

Make moving to another country as simple as possible for employers and employees

In an increasingly connected world, employers need to get the best out of their employees for them to remain competitive and thrive. Remote and international working has become the norm. Employers must handle UK and overseas tax obligations, whilst providing the best working environment to attract and retain talent. 

Common global mobility considerations for employers

  • Are you a UK based company with employees working overseas temporarily or permanently?
  • Are your employees frequently asking to work remotely internationally?
  • Are you an overseas company considering setting up in the UK, employing UK based staff and/or relocating existing overseas staff to work in the UK?
  • Do you have non-UK resident directors?
  • Do you have overseas employees undertaking workdays in the UK?

Our global mobility specialists take the time to understand your businesses objectives and align them your employees goals. We provide support across all aspects of international employment tax.

How can PKF Francis Clark help? 

Ideally, advice should be sought before any cross-border working begins. We can:

  • Review the current and expected UK tax residency position of the employee 

  • Identify and assist with the company’s employment tax obligations (payroll, withholding tax, social security) and wider corporate issues (permanent establishment, corporate residence etc) 

  • Help the employee understand their personal tax obligations and provide practical support 

  • Provide advice and assistance with obtaining relaxations of strict withholding tax and social security requirements 

  • Assist with multi-country compliance and reporting requirements for both employers and employees 

  • Advise on the tax consequences of a UK company engaging foreign-based directors 

  • Assess tax efficient international expenses, benefits and relocation packages 

  • Prepare and submit applications to obtain HMRC agreement for international employment tax and social security matters 

  • Provide referrals to overseas advisors and employment law/immigration specialists 

Bringing clarity to the complexities of global mobility

Ideally, advice should be sought before any cross-border working begins. We can help:

  • Review the current and expected UK tax residency position of the employee

  • Identify and assist with the company’s employment tax and wider tax obligations

  • Help the employee understand their personal tax obligations and provide practical support

  • Provide advice and assistance with obtaining relaxations of strict withholding tax and social security requirements

  • Assist with multi-country compliance and reporting requirements for both employers and employees

  • Advise on the tax consequences of a UK company engaging foreign-based directors

  • Assess tax efficient international expenses, benefits and relocation packages

  • Prepare and submit applications to obtain HMRC agreement for international employment tax and social security matters

  • Provide referrals to overseas advisors and employment law and immigration specialists

Managing the tax risks of having a globally mobile workforce

We can help with the following:

Permanant establishment

Inadvertently establishing a taxable presence of the employing company in the host jurisdiction and potential exposure to the host’s corporation tax regime. This could include working from a home office overseas.

Tax and payroll compliance

Managing overseas employment tax and social security compliance obligations such as registration, running a local payroll, applying local withholding tax and (employee and/or employer) social security.

Personal tax implications

Both reporting and payment, often depending on the employees’ tax residence status.

Double tax

Employees may find themselves subject to tax in their home and in the host country on the same income. It may be possible to minimise double tax (but not always).

Social security

For both the employee and the employer. If no action is taken, double social security charges could apply.

Directors tax rules

There are stringent UK tax compliance rules for ‘non-resident directors’ (potentially even just for one UK day/meeting a year).

Expenses and benefits

Any expenses and benefits may also be subject to the home and host country’s tax and social security unless an exemption applies.

Non-tax issues

Overseas employment law, immigration and insurance.

Frequently asked questions

Yes. Whether the employee is working from their own overseas home or in an overseas office, the employment tax implications will be the same. The legislation is designed to look at where the employees’ duties are physically being performed (be that in an employer’s office or at home).

This depends on where the individual is working, how long for and what they are doing. Under the Organisation for Economic Coordination and Development’s (OECD) model tax convention, employment income may remain taxable in the UK, and avoid overseas tax, for a UK treaty resident individual (this will need to be established) if they meet specific conditions. Advice from an experienced global mobility professional should always be obtained in the first instance.

A1 certificates (different to a Certificate of Coverage) are usually issued by an individual’s home tax authority which provides formal evidence that the individual should remain within the scope of their home social security system and outside that of their temporary working location.

Professional advice should be obtained as the relevant social security legislation needs to be explained.

A section 690 (S.690) direction is a PAYE relaxation agreement, issued by HMRC.

It refers to an employee’s earnings for UK work if they are non-resident, UK resident but treaty non-resident or UK resident but entitled to Overseas Workday Relief. Specific conditions apply and obligations follow (e.g. submitting a UK tax return).

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Meet our global mobility experts

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We’ll provide expert tax advice to support your international operations – and as part of the PKF global network we can call on members in 150 countries to make sure you get the best advice.

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