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The 2017 Global HR conference
International Assignments & Business Traveller Update Andrew Bailey, Head of Global Expatriate Services - BDO LLP 6 February 2017 Image title slide (Slide layout option: Title Slide-Image) An alternative image title slide is available. The image on this slide is an example of an approved image from the BDO Brand Centre*, any of which can be used as an alternative to the colour block title slide. Images should be scaled to align with the typographic grid and should be of sufficient size to fit within this space at 96ppi resolution. Colour images to be used in your presentation should be specified as RGB colour. Please note that the image in this template is included as a placeholder example only. Headings and subheadings are preset to appear in BDO Red. The third line of a title, if necessary, is set to appear in BDO Teal. When placing text on an image please always use BDO Red or white text. * If you wish to use this image it must be purchased. Please visit the BDO Brand Centre for more information
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The 2017 Global HR Conference – 6 February 2017
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General Developments in the tax world
Moral Debate Corporate reputation Power of the consumer Turning of the tide Compliance and a shrinking world Automatic exchange of information/Common Reporting Standards Accompanying legislation and practice Newsworthy Text slide with title and body text (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary. Note: The presentation footer includes the Client name, event details and the Presentation title. You can change these details. To make a change to the footer details, click ‘Insert’ from the PowerPoint ribbon. From the Text tab, click on ‘Header and Footer’, a dialogue box will open. To change the Footer text, simply overtype the sample text that appears in the ‘Footer’ area of the dialogue box. The details will be updated on all presentation slides that include the footer text. It is not necessary to change any of the other options on this panel. The 2017 Global HR Conference – 6 February 2017
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General Developments in the tax world
Cost containment International assignees expensive Failed assignments/return on investment Shorter/commuter assignments Policy adaptation Overarching policy Multiple sub-polices Reducing cost The 2017 Global HR Conference – 6 February 2017
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2016 BDO/santa fe global mobility survey
Key Trends Net growth in assignment over next 12 months +30% +22% +21% +13% +10% +3% +2% Strategic long-term assignments Short-term business travellers Short-term assignments One-way relocations (company initiated) One-way relocations (employee initiated) Graduate programmes Commuter assignments Developmental long-term assignments -1% The 2017 Global HR Conference – 6 February 2017
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Most frequent sending and receiving countries
Countries sending to (% most common) Countries sending from (% most common) USA 16% USA 17% China 12% UK 13% UK 7% China 6% Singapore 6% France 6% France 4% Australia 5% Germany 4% Germany 5% UAE 4% India 3% Hong Kong 4% Australia 3% China and India continue to be most challenging destinations China – 13% (previously #1) India – 7% (previously #2) Brazil – 5% (previously #4) USA – 5% (previously #5) Russia – 4% (previously #3) Table example with supporting text (Slide layout option: Title and Text over Content) The table shown in this example slide is for style reference purposes only and shows the 14pt. Trebuchet MS minimum recommended sizes for table information, along with a visual guide to borders and fills of table cells in PowerPoint editable tables. You may use this example as reference only or copy and paste this as a starting point for further tables in your presentation. The 2017 Global HR Conference – 6 February 2017
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business travellers Treaty exemption BEPS Action Plans 183 day myth
Other conditions – employer & who bears the cost? BEPS Action Plans Action Point 7 – Preventing the artificial avoidance of permanent establishment status Action Points 8-10 & 13 – Aligning transfer pricing outcomes with value creation Text slide with title and body text (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary. Note: The presentation footer includes the Client name, event details and the Presentation title. You can change these details. To make a change to the footer details, click ‘Insert’ from the PowerPoint ribbon. From the Text tab, click on ‘Header and Footer’, a dialogue box will open. To change the Footer text, simply overtype the sample text that appears in the ‘Footer’ area of the dialogue box. The details will be updated on all presentation slides that include the footer text. It is not necessary to change any of the other options on this panel. The 2017 Global HR Conference – 6 February 2017
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The 2017 Global HR Conference – 6 February 2017
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The 2017 Global HR Conference – 6 February 2017
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The 2017 Global HR Conference – 6 February 2017
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Source https://www.gov.uk/hmrc-internal-manuals/paye-manual/paye82000
The 2017 Global HR Conference – 6 February 2017
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business travellers Short Term Business Travellers Data Collection
Major topic Treaty rules Treaty and withholding interaction Tracking Data Collection Biggest challenge? Bringing it all together – new technology tools e.g. BDO QuickTrip – launching today Text slide with title and body text (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary. Note: The presentation footer includes the Client name, event details and the Presentation title. You can change these details. To make a change to the footer details, click ‘Insert’ from the PowerPoint ribbon. From the Text tab, click on ‘Header and Footer’, a dialogue box will open. To change the Footer text, simply overtype the sample text that appears in the ‘Footer’ area of the dialogue box. The details will be updated on all presentation slides that include the footer text. It is not necessary to change any of the other options on this panel. The 2017 Global HR Conference – 6 February 2017
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The 2017 Global HR Conference – 6 February 2017
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Global Mobility vs Travel Manager Compliance means different things
Immigration Compliance Are they travelling on the correct visa ? Booking Tool Compliance Are they using the company provided tool? Taxation Compliance How many days have they spent in the UK ? Supplier Compliance Are they booking Marriott when they should be booking Hilton ? Duty of Care Where are they and how can I find them ? Duty of Care Where are they and how can I find them The 2017 Global HR Conference – 6 February 2017 The 2017 Global HR Conference – 6 February 2017
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business travellers - SUMMARY
Business travellers can give rise to individual liabilities, withholding implications for the entity and compliance obligations for both individual and the business Business travellers are a significant risk in the creation of a Permanent Establishment Significant set-up maintenance costs and ongoing taxation obligations What they do in that country could now drive a Corporation Tax Liability. It’s no longer only about a personal income tax gross up or withholding liability. Finance and Legal will be much more involved in who is where – and what they are doing – from where do they get the data? Do you have the data to supply ? Immigration and Revenue authorities are sharing information much more frequently to match purpose of work with Visa status +100 Countries have signed up to AEOI principles Revenue and Immigration authorities will/do require an ‘adequate process’ for monitoring and recording business travel IN SHORT - YOU CAN’T IGNORE BUSINESS TRAVELLERS - THE TAX IMPLICATIONS ARE GROWING Text slide with title and body text (Slide layout option: Title and Content) This slide exists as a ‘slide master’. Text is entered directly into the prompt boxes provided when a new ‘Title and Content’ slide is inserted from the slide layout options. The ‘slide master’ also includes the correctly sized and positioned BDO logotype and other graphic elements. All the slide title text is in BDO Red, Trebuchet MS bold, upper case. Where there is a sub-heading, the second line should be changed to BDO Teal. Within body text, subheadings should be set at the same size in Trebuchet MS Bold, BDO Red. To advance to each level from the previous one, select ‘Increase List Level’ on the ‘Paragraph’ ribbon tab. To return to the previous level, select ‘Decrease List Level’ on the ‘Paragraph’ ribbon tab. The starting position of the text is fixed but the text box will grow if text extends beyond the depth determined by the ‘slide master’. Care should be taken to keep text within the boundary of the bottom margin. Start a new page if necessary. Note: The presentation footer includes the Client name, event details and the Presentation title. You can change these details. To make a change to the footer details, click ‘Insert’ from the PowerPoint ribbon. From the Text tab, click on ‘Header and Footer’, a dialogue box will open. To change the Footer text, simply overtype the sample text that appears in the ‘Footer’ area of the dialogue box. The details will be updated on all presentation slides that include the footer text. It is not necessary to change any of the other options on this panel. The 2017 Global HR Conference – 6 February 2017
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ABOUT BDO International
We would also like to highlight: As one of the world’s largest accountancy networks, we offer the full range of service offerings you would expect of a firm of our calibre and quality We operate in areas that are important to you now and in areas where you will want to be in the future Ours is not an alliance of disparate independent firms, but a single network of member firms all bound by the same dedication to client service. Our international figures include exclusive alliances of BDO Member Firms. The 2017 Global HR Conference – 6 February 2017
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BIOGRAPHY Andrew Bailey Head of Global Expatriate Services
Direct: +44 (0) Mobile: +44(0) Sector expertise Head of Global Expatriate Services and National Head of Human Capital Services responsible for BDO LLP's Human Capital offering encompassing expatriate tax, reward & performance and employment tax - how to get the best return from investment in & interaction with employees. I specialise in expatriate tax, providing guidance to employers and employees either moving to or from the UK, together with worldwide international coordination of expatriate programmes. Over 30 years experience in this area. Biography slide (Slide layout option: Biography) Replace the sample text with the individual’s details using the heading titles given in the sample text, beginning with the person’s name, title, address and contact details. Click the image box to insert an approved image of the individual and align the image to fit the typographic grid. Please refer to imagery guidelines for portrait photography guidance. The 2017 Global HR Conference – 6 February 2017
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