Global mobility: designing a program that doesn't break legal, tax, or trust
Moving employees across borders touches immigration, tax, payroll, social security, equity, and personal life. Here's the program design — tiers, eligibility…
- Three tiers: short-term assignment, long-term assignment, permanent transfer. Different rules each.
- Tax equalisation vs tax protection vs laissez-faire — pick one philosophy per tier.
- Permanent establishment risk is the silent killer. Loop tax in before the move.
- Equity travels badly. Plan the grant treatment before the visa, not after.
Global mobility looks like an HR problem. It's actually a tax, legal, and finance problem with HR holding the relationship. The fastest way to lose six figures is to let an employee move 'temporarily' for 200+ days without a plan.
The three tiers
| Tier | Duration | Typical use | Complexity |
|---|---|---|---|
| Short-term assignment | <6 months | Project, training, customer support | Low — usually home payroll |
| Long-term assignment | 6 months - 5 years | Open new market, leadership rotation | High — split payroll, tax equalisation |
| Permanent transfer | Indefinite | Personal choice, market move | Medium — full localisation |
Owners + RACI
- HR: relationship, policy, communication.
- Tax / Finance: residency, equalisation, payroll split, permanent establishment risk.
- Legal / Immigration: visa, work authorisation, dependents.
- External providers: tax adviser, immigration counsel, mobility platform.
- Manager: business case + scope clarity for the new geography.
Tax philosophy
- Employee pays hypothetical home tax
- Company makes them whole on real tax
- Predictable for employee
- Complex + expensive for company
- Employee bears actual tax
- Company tops up only if higher than home
- Simpler for company
- Employee bears the variance
The four expensive traps
- Permanent establishment: 1 senior employee in a new country can create taxable presence for the company. Tax adviser before the move.
- Social security: bilateral treaties (totalisation) exist between some countries. Without one, you may pay twice.
- Equity at vest in a new country: tax may apply on cross-border vesting. Plan equity treatment before the move.
- Trailing liabilities: tax filings due 1-2 years after return. Budget for the close-out.
Tier definitions, who pays for what, tax philosophy per tier, named providers, escalation contact, repatriation plan. If you can't write that one-pager, you don't have a program — you have a series of expensive exceptions.
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