Global Mobility

This book covers the tax and social security implications of international assignments, both for the individual and for the employer. It also covers the HR aspects, including the structure of expatriate remuneration.

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About this work

The focus of this book is on employees moving to and from the UK for work, usually on assignment. It covers the tax and social security implications of the assignment both for the individual and for the employer. It also covers the HR aspects of employee assignments overseas, including the structure of expatriate remuneration.

For many readers, this book complements another Claritax title, Advising British Expats – Tax Compliance and Planning. That other book primarily explains the UK tax implications of British expats living overseas for whatever reason.

Table of contents

• Introductory material
• Mobility as a lifestyle
• The macro view of internationally mobile employees
• The legal framework
• The international workforce
• Optimising team and process
• Care and career aspects of global mobility
• UK tax implications – the basics
• Determining tax residence
• Taxation of income and gains generally
• Taxation of expatriate earnings
• Taxation of specific employees
• Double taxation [expanded by way of example]
  • Introduction
  • Double tax treaties – principles
  • Double tax treaties – articles most relevant to employees [expanded by way of example]
    • Introduction
    • Article 4 – resident – principles
    • Article 4 – resident – McCabe
    • Article 4 – resident – habitual abode
    • Article 4 – resident – other considerations
    • Article 5 – permanent establishment
    • Article 15 – income from employment – principles
    • Article 15 – income from employment – 60-day rule
    • Article 16 – directors’ fees
    • Article 18 – pensions
    • Article 19 – government service
    • Academics
    • Articles 23A and 23B – double tax relief
  • Unilateral relief
• Taxation of foreign income and gains
• NIC and social security
• Expatriate PAYE employer agreements and obligations
• Employee obligations