• Delivering for today, planning for tomorrow?

    EY can help you understand the implications of the EU referendum decision on your tax position.

  • UK votes to leave

    Read our analysis of Brexit and the potential implications for business and the economy.

  • Tax Insights: the rising importance of tax talent

    See our latest edition to learn how leading companies are recruiting and developing tax talent, to understand how tax is being transformed worldwide and more.

  • Budget 2016

    Read all our commentary, thought leadership and insight into Budget 2016.

  • Year End Personal Planning Tax Guide 2015/16

    Highlights some of the major issues and areas we think it prudent for taxpayers to consider as the end of the tax year approaches.

  • Indirect tax developments in 2016

    We highlight the significant volume and breadth of indirect tax changes across the globe, allowing you to consider their impact, potential opportunities and obligations.

  • Global sustainability taxes

    Discover which three areas of tax policy can help CFOs and tax directors navigate through environmental and sustainability changes happening today.

  • Global digital tax developments

    How are digital tax trends evolving around the world? EY offers a deep dive of the latest developments.

  • Striking a balance

    How far should HMRC dictate to business, and should tax administrators use compliance rather than legislation to achieve objectives? It’s about striking a balance between enabling and mandating.

Tax Services

We’ll help you navigate the global tax landscape

The business and tax landscapes have changed dramatically, and the pace and complexity of change continues to increase. Governments are tempering the need for revenue with increased competition for labor and capital. Tax authorities are adapting their enforcement strategies, focus and policies in response to the changing dynamics of business. Companies are balancing competing priorities, ensuring they maintain compliance while adding value.

We can assist you with these critical issues in today's tax environment, including:

EY - Building a business tax blueprint for the UK

Building a business tax blueprint for the UK post-Brexit

We asked over 175 tax and finance professionals headquartered in the UK and overseas for their views on how the tax system affects the UK’s attractiveness post-Brexit. Read more 1.4Mb, September 2016


Improving large business tax compliance:

EY Building the balance: Cooperative compliance in practice

Building the balance: Cooperative compliance in practice

The administration of our tax regime is a key factor in the attractiveness of the UK as a place to live and do business. Our report outlines the proposed agreement and offers a view on the most effective way to take it forward. Read more 2.1Mb, March 2016

Engaging with HMRC
255K, July 2015
New measures applicable from April or July 2016
494K, December 2015
Corporate Governance Code meets Tax Code of Practice
203K, July 2015

  • Midweek Tax News


    A weekly update on tax matters to 18 October 2016

    Midweek Tax News provides you with a succinct overview of the key tax developments that have occurred each week to allow you to stay up-to-date on tax issues that may have an impact on your business. If you would like to discuss an article in more detail, please speak to the relevant contact listed at the end of this issue or to your usual EY contact.

    On Friday, 14 October 2016, HMRC hosted a meeting on Country-by-Country Reporting (CBCR), attended by a mixture of advisers and industry participants across a range of sectors. The meeting covered a number of areas relating to the practicalities of submitting a report.

    At the meeting, HMRC confirmed that additional regulations will be issued to address the OECD rules on transparent entities and investment entities being ultimate parent entities, as well as implementing changes to align the UK rules with the EU notification requirements contained in the 4th Directive on Administrative Cooperation. Regulations will also be issued to grant powers for HMRC to request local UK filers to obtain their ultimate parent's full Country-by-Country report.

    The meeting covered the IT and systems related issues relevant to CBCR, including the most appropriate mechanism for submitting the report and issuing confirmation of receipt. It is expected that the submission system will be open by 1 July 2017. It was also noted that there will be a common transmission solution across the OECD and the EU for the exchange of reports, though there will be no OECD central database to collate reports received. The UK data protection laws will apply to data exchanged by HMRC on UK ultimate parents.

    It was also reiterated that UK local filers have an obligation to file a Country-by-Country report until their ultimate parent files a group report. If the ultimate parent does not file when the UK entity had understood it would, HMRC will consider ‘reasonable excuse’ arguments to mitigate exposure to penalties, especially in the first year.

    On 13 October 2016, the US Internal Revenue Service and Treasury Department released the much-anticipated final and temporary regulations (TD 9790) under Section 385. The regulations are expected to be effective on 21 October 2016.

    The final and temporary regulations:

    Treat as stock certain related-party interests that otherwise would be treated as indebtedness for federal tax purposes (the Recharacterization Rule); and

    Establish extensive documentation requirements with respect to related-party indebtedness (the Documentation Rule).

    The Recharacterization Rule generally applies to tax years ending on or after 90 days after the final regulations are published in the Federal Register (i.e. January 2017). It does not apply to debt instruments issued prior to 5 April 2016. The Documentation Rule generally applies to debt instruments issued on or after 1 January 2018.

    The final and temporary regulations make substantial changes to the proposed regulations that were released in April 2016, such as:

    Excluding foreign issuers – the final and temporary regulations apply only to domestic corporations (including certain partnerships and disregarded entities with domestic corporate owners);

    Excluding certain financial institutions – the Recharacterization Rule generally does not apply to debt instruments issued by certain regulated financial entities, financial groups and insurance companies;

    Eliminating the ‘bifurcation rule’ – the final and temporary regulations do not include the ‘bifurcation rule’ included in the proposed regulations, under which the IRS was permitted to characterise certain instruments within a ‘modified expanded group’ as part debt and part stock;

    Delaying the Documentation Rule requirements – the Documentation Rule does not apply to debt instruments issued before 1 January 2018.

    The final and temporary regulations contain numerous other changes to the proposed regulations including a widely-anticipated cash pooling exception, expanded exceptions for ordinary course transactions, exceptions for S-corporations and certain other entities subject to special treatment under the Internal Revenue Code, and exceptions for statutory debt instruments.

    EY will be hosting a webcast on Wednesday, 19 October 2016 at 5:00 pm to analyse the changes from the originally proposed regulations and to consider what needs to be done now to comply with the final regulations. To register for this event, please click here.

    In last week's Midweek Tax News we covered the first day of the OECD's two day public consultation on transfer pricing matters, which focused upon the attribution of profits to permanent establishments. The second day, held on 12 October 2016, focused upon the revised guidance on profit splits.

    The discussion draft sought to clarify and strengthen the guidance on the transactional profit split method in the context of global value chains. In particular, it considered the approaches to splitting profits through transactional profit splits of actual profits and transactional profit splits of anticipated profits. It also proposed further draft guidance on the appropriate application of transactional profit split methods.

    The opening statements to the second day focused on when the profit split method should be applied, with the Business International Advisory Committee (BIAC), representing international business, stressing the primacy of the most appropriate method and the need to protect the arm's length principle. The most appropriate method is the principle that any transfer pricing method should be assessed against alternative transfer pricing methods, taking into account the facts of the situation and the availability of data, in order to choose the most appropriate method. BIAC argued that the profit split method should not be used as a default option, suggesting that in some situations, a profit split would be too complicated. They called for more detail and a wider range of examples in the guidance to ensure that the profit split method would be applied consistently. They also wanted to see more guidance on valuation and the application of profit splits to ongoing transactions.

    By comparison, the BEPS monitoring group called for the systemisation of the profit split method. They believe that, sooner or later, some form of unitary taxation model will need to be applied to multinational enterprises. They believe the profit split method should not be used as a ‘fall back’, suggesting that in many cases there is significant value contributed by members of an integrated multinational group. This ‘synergy profit’ is, in their view the root of the problems with taxing multinationals. Their concern is that if the profit split method continues to be used on an ad hoc basis, this will only add to these difficulties.

    In our response to the discussion draft, we also expressed the view that the well-established principle of assessing the most appropriate method should be preserved. The next step is for OECD Working Party 6 to discuss all the comments raised at its next meeting in November.

    More detail on the public consultation meeting is available in our global tax alert.

    The High Court has delivered its judgment in Lomas & Ors, which considered whether the payment of statutory interest arising under the Insolvency Rules 1986 to the creditors of Lehman Brothers International (Europe) could be made without the deduction of tax.

    The Joint Administrators submitted that the statutory interest to be paid did not accrue from time to time over any period and so was not ‘yearly interest’. If this were the case, the Joint Administrators would not be required to deduct basic rate income tax from the payments. Initially, HMRC agreed and gave a number of confirmations to that effect. However, on reviewing the issue, HMRC altered its position and subsequently contended that the statutory interest was ‘yearly interest’ and as such a distribution of statutory interest should be subject to deduction of income tax at source. HMRC contended that the statutory interest payable was calculated and payable in respect of periods in excess of a year, commencing at the time of the commencement of the administration.

    Although it was common ground that such statutory interest was indeed ‘interest’ for the purposes of tax legislation, the Court considered that it was of a very different nature from that payable on contractual debts, judgment debts or other analogous debts. The Court considered that the right to payment out of a surplus of statutory interest under the Insolvency Rules was in the nature of an arrangement statutorily imposed on the creditors for the equitable distribution of surplus. This seemed to the Court to be some way away from any of the tax cases where the payment or commitment to pay interest had been determined to be in the nature of ‘yearly interest’. There was no loan, no investment, no judgment, no period of accrual, no right unless and until a surplus was established, no quality or capability of recurrence, only a moratorium and a scheme of distribution mandated by the statute and the Insolvency Rules.

    Accordingly, the High Court held that the statutory interest did not amount to yearly interest.

    This case provides a useful summary of the case law around yearly interest and highlights the uncertainty that can still exist in this area despite established practice and published guidance. It should be noted that HMRC has been granted leave to appeal and is currently considering whether to pursue an appeal.

    HMRC publishes updated guidance on the tax implications of new UK GAAP

    HMRC has now published updates to its guidance on the introduction of new UK GAAP (either FRS 101 or FRS 102) which sets out the key accounting changes as well as the key tax considerations that could arise for those companies transitioning from old UK GAAP to the new standards.

    While there are only limited updates to the guidance, HMRC has again said that it will be looking at transitional adjustments closely. The issue of explanations around the transition to new UK GAAP (including reconciliations) is believed to be a particular area of focus for HMRC, especially the distinction between prior period error corrections and changes in accounting policy, which can have a material impact on the tax treatment. HMRC is also understood to be interested in the accuracy and relevance of the accounting policy descriptions.

    Please get in touch with your usual EY contact if you would like to discuss any issues as a result of adoption of the new accounting standards.

    Tax transparency – Financial Reporting Council year-end guidance

    The Financial Reporting Council (FRC) has now issued its year-end guidance to preparers of financial statements. This guidance contained some initial comments on tax disclosures that reflected findings from the thematic review it undertook in 2016.

    The FRC suggested that there remains scope for greater visibility of the factors which are relevant to effective tax rates and their sustainability. The FRC added that companies should articulate better how they account for material tax uncertainties by explaining the bases for recognition and measurement and noted that it expected more companies to disclose the amount of their provisions for tax uncertainties than do so presently.

    The FRC added that companies' tax arrangements are an area of increasing public focus, which can give rise to significant risk. Accordingly it said that “Companies need to respond to increasing stakeholder scrutiny of their tax strategies, including where they pay tax, and to consider carefully whether they are sustainable and any material risks to which this gives rise are clearly described in the report and accounts.”

    The FRC's report following its thematic review of tax reporting will be published later this month.

    Corporate failure to prevent facilitation of tax evasion included in Criminal Finances Bill

    The Criminal Finances Bill, published on 13 October 2016, amends the Proceeds of Crime Act 2002 and contains legislation to introduce the new corporate criminal offence of failure to prevent facilitation of tax evasion, with separate provisions for UK and foreign tax evasion offences.

    HMRC consulted on the new offence during 2015 and released a version of the legislation and draft guidance for comment between April and July.

    The Bill is in four parts, with the third part of the Bill introducing the two new corporate offences of failure to prevent facilitation of tax evasion, one in relation to UK taxes and the other for foreign tax evasion offences. There is also a requirement for the Government to publish guidance about the procedures that relevant bodies might put in place in relation to these offences.

    There is no date set as yet for the second reading of the Bill.

    Brexit – what next for banks?

    Whilst the UK Government is looking to serve notice under Article 50 of the Treaty of the European Union before the end of March 2017, there still seems to be little consensus between the UK, the other EU Member States and the European Commission as to what any ongoing relationship should look like.

    It is inherently difficult to describe and model the implications of the numerous possible scenarios which may flow from the UK's withdrawal from the EU. These will vary greatly depending on an individual group's particular business model, governance and organisation structure, as well as its degree of exposure to EU markets outside the UK. However, there are a number of broad themes which may be relevant to a range of banks currently operating throughout Europe from a UK platform.

    In our latest report, Brexit – what next for banks?, we consider six potential scenarios which identify many of the tax considerations associated with various potential responses to Brexit. In each scenario we have highlighted the key UK tax considerations in relation to the restructuring and, for illustrative purposes, provided commentary on a number of European jurisdictions in which new entities may be established.

    The report is available here.

    It should also be noted that the High Court judicial review into the Prime Minister's ability to trigger Article 50 without deferring to Parliament finished yesterday, 18 October 2016. Although the high court promised to give its verdict as quickly as possible, it is likely that an appeal to the Supreme Court will follow regardless of the decision. It is expected that such an appeal would be heard before the end of the year.

    House of Lords Inquiry into effect of Brexit on service industries

    The House of Lords EU Internal Market Sub-Committee has launched a short inquiry on ‘Brexit: Trade in services between the UK and the EU’. This follows on from the Committee's short inquiry into ‘Brexit: Future trade between the UK and the EU’, which held its last oral evidence session on Thursday, 13 October 2016. The Committee is seeking to examine what terms of market access key service sectors in the UK would like to have with the EU.

    The inquiry begins with a public meeting this Thursday, 20 October, at which experts will give evidence on how services are traded between the UK and the EU at the moment. Subsequent evidence sessions will focus on the key sectors of digital and telecommunications, professional business services, aviation and creative and broadcasting.

    There is no public call for evidence as part of the inquiry, though submissions can be made to the Committee, no later than 31 October 2016.

    Upper Tribunal holds that supplies made to exhibition stallholders are not an exempt supply of land

    The Upper Tribunal has released its decision in the case of Kati Zombory-Moldovan t/a Craft Carnival. The taxpayer organises craft and garden fairs, selling spaces to businesses and individuals involved in various crafts to enable them to sell products at those events. The taxpayer accounted for VAT on the admission fees paid by the public but not on the supply of spaces to stallholders, which were treated as an exempt supply of land. HMRC contended that the supplies to stallholders were a composite supply of taxable services comprising the organisation of a craft fair, the purpose of which was to provide the stallholders with an opportunity to trade.

    Based on a review of the contractual arrangements and the economic reality of the situation, the Upper Tribunal concluded that the taxpayer had very real and significant responsibilities beyond the bare provision of an appropriately-sized plot, which meant that, in its view, the stallholder fee could not be treated as a separate exempt supply of land. In contrast to the First-tier Tribunal decision, the Upper Tribunal held that the supply of an allocated space to stallholders was part of a single taxable supply of participation as a seller in a high-quality, expertly organised and run craft and garden fair, one element of which was the provision of a pitch.

    The Upper Tribunal decision in this case supports the First-tier Tribunal decision in the case of International Antiques and Collectors Fairs and adds further weight to the volume of case law concerning composite supplies for VAT purposes. It reconfirms the approach that taxpayers combining a mixture of supplies, which in their own right might attract separate rates of VAT, need to pay close attention to the overall supply being made and whether the individual supplies can in fact be differentiated.

    International developments

    Luxembourg publishes its fiscal budget for 2017

    On 12 October 2016, the Luxembourg Government introduced into Parliament a Bill outlining the budgetary measures for 2017 (the Budget Law).

    The Budget Law proposes the introduction of a new article into the Luxembourg Income Tax law (ITL) that aims to clarify the concept of the arm's length principle. This new article contains the basic elements to be respected in the framework of a transfer pricing analysis, based on the OECD's transfer pricing guidelines in their revised form following the BEPS Actions 8-10 final report. This new article particularly focuses on the comparability analysis and contains new elements to be considered, transposing the conclusions from Actions 8-10 of the BEPS work into domestic law.

    Furthermore, and to comply with European legislation, the Budget Law proposes some amendments regarding the real estate tax regime for charitable and non-profit organizations, and the removal of the requirement for a guarantee against the collection of tax for EU non-residents willing to establish their residence in Luxembourg. The Budget Law also sets out an amendment to the Value Added Tax (VAT) regime for small and medium-sized companies.

    An alert is available here.

    Outcomes of the ECOFIN meeting on 11 October 2016

    Following the ECOFIN meeting on 11 October 2016, the Council adopted conclusions in response to a European Commission communication on tax transparency following the April 2016 ‘Panama Papers’ revelations. The conclusions highlight the continued need to prevent the large-scale concealment of funds, which hinders efforts to clamp down on tax evasion, money laundering and terrorist financing.

    In its July 2016 communication, the European Commission recommended a coordinated approach to preventing tax abuse, at both EU and international levels. Whilst progress has been made at EU level, the Council noted that loopholes remain and further action is envisaged.

    The Council also approved a taxation agreement with Monaco, giving tax administrations improved cross-border access to information on the financial accounts of each other's residents.

    The Council also adopted a decision allowing Poland a VAT derogation for certain road vehicles.

    OECD launches business survey on tax certainty

    Yesterday, 18 October, the OECD launched a survey, inviting businesses and other stakeholders to contribute their views on tax certainty. The survey is an open consultation which will support the G20 future tax policy work. It follows on from statements at the recent Hangzhou Summit by the G20 Leaders on the benefits of tax certainty in promoting investment, trade and balanced growth and was trailed in the OECD update webcast of 22 September (see Midweek Tax News to 27 September).

    The survey will run from 18 October to 16 December 2016 and is intended to provide the opportunity to share experience, identify specific tax policy issues for the future G20 tax agenda and shape practical and concrete solutions for a more certain and predictable tax system. An OECD webinar, giving the chance to raise questions on the survey, is scheduled for 25 October. It is intended that responses should reflect the view of a firm or group as a whole.

    The survey is anonymous; no individual or organisation-specific information will be disclosed. Results will only be made available in aggregated format and presented to the G20 in 2017.

    Other global tax alerts

    Please see links to a selection of our tax alerts in respect of the following developments. Additional articles are available in our global tax alert library.

    Ireland: As part of the 2017 Budget proposals, the Irish Minister for Finance has published an update on Ireland's international tax strategy.

    Norway: Norway introduces Country-by-Country Reporting.

    Switzerland: The Swiss Supreme Court denies the deductibility of punitive fines for corporate tax purposes.

    Uruguay: Uruguay modifies regulations to conform to National Budget Law, providing certain tax reductions.

    Other publications

    Please speak to your usual EY contact, or email us at eytaxnews@uk.ey.com, if you would like to receive a copy of our regular indirect tax newsletter or our employment, reward and mobility newsletter, as well as information about our other publications.

    Further information

    If you would like to discuss any of the articles in this week's edition of Midweek Tax News, please contact the individuals listed below, Claire Hooper (+ 44 20 7951 2486), or your usual EY contact.

    HMRC meeting on Country-by-Country Reporting

    Email Claire Hooper

    + 44 20 7951 2486

    US IRS releases final and temporary Section 385 regulations

    Email Cliff Tegel

    + 44 20 7951 1417

    OECD public consultation on attribution of profits to permanent establishments and profit splits

    Email Gary Mills

    + 44 20 7951 1608

    Email Andy Martyn
    + 44 20 7951 9539

    High Court judgment considers statutory interest is not ‘yearly interest’

    Email Andrew Drysch

    + 44 20 7951 7076

    For other queries or comments please email eytaxnews@uk.ey.com.

    Back to the top

  • Operating in a shifting tax landscape

    The global tax landscape continues to change in a dramatic fashion, with near-constant news hitting the headlines regarding shifting tax policy, increasing levels of enforcement and the growing potential of reputational risk.

    Competing priorities

    Multinational companies now have to balance more competing priorities than ever before, ensuring they protect their business by monitoring and responding to changes in policy, legislation and tax enforcement, while at the same time ensuring they not only maintain the highest levels of compliance but also add value from the tax function.

    Governments work to secure each tax dollar they're due

    From a policy perspective, all governments want their country to be viewed as an attractive place to do business, to attract jobs and capital in an increasingly competitive globalized arena.

    At the same time, they want to increase the amount of revenue they bring in. Governments are treading a fine line, constantly assessing how to secure the tax revenues they see as rightly theirs, while at the same time being in direct competition with other nations, making sure they do not scare off mobile capital.

    Tax administrations for their part are adapting their enforcement strategies, focus and policies in response to the changing dynamics of business. They are working to ensure that their resources are being applied to the right issues and taxpayers. They share more leading practices and taxpayer information with their foreign counterparts, to help them collect every dollar due.

    Disputes are on the rise

    The result has been more  frequent, complex and higher value disputes between taxpayers and taxing authorities — a trend that is only increasing as countries collaborate together and as emerging markets gain in stature and influence, taking a more sophisticated approach to taxation. Penalties are becoming more stringent and the threat of reputational risk has risen significantly in recent months.

    We can help you to navigate a route through this complex landscape.

    We can help you monitor and react to quickly-changing tax policy and assess the economic and fiscal impact.

    Where tax policies might create an impediment to your business that is unintended by policy makers, we can help you to collaborate – either solely, or as part of a broader grouping of companies who share a common objective – with government to:

    • Explain the impediment
    • Develop alternative policy choices which are logical and well thought out
    • Model the potential outcomes
    • Deliver an alternative choice to the government in a form with which policy makers can comfortably work

    We also help you address your global tax controversy, enforcement and disclosure needs.

    We focus on pre-filing controversy management to help you properly and consistently file your returns and prepare the relevant back-up documentation.

    Where a controversy has already occurred, our professionals leverage the network's collective knowledge of how tax authorities operate, and increasingly work together, to help resolve difficult or sensitive tax disputes. To ensure that continuous performance improvements are instigated after a controversy, we work with EY's other tax professionals to ensure that similar events are less likely to occur.

    Below you can access our views and analysis of some of the substantial policy and enforcement trends and issues at play today.

    Related content


    Alternative Dispute Resolution: a new chapter emerges

    As tax authorities adapt their enforcement in response to changing business dynamics, so must taxpayers. One key is the knowledge of alternative dispute resolution tools.

  • Seizing the opportunity in Global Compliance and Reporting

    Global Compliance and Reporting (GCR) is at a tipping point, with risks on the rise. Many companies distribute responsibility for GCR processes throughout their organization, creating a patchwork. Local jurisdictions are rewriting regulations, focusing more intently on the collection of tax revenues and sharing more taxpayer information across borders.

    Due to the combination of evolving business models, transforming finance functions and an increasingly complex regulatory landscape, there are new opportunities to better optimize efficiency, control and value, to help mitigate risk and improve performance.

    What is Global Compliance and Reporting?

    GCR comprises the key elements of a company's finance and tax processes that prepare statutory financial and tax filings as required in countries around the world. These duties include:

    • Statutory accounting and reporting
    • Tax accounting and provisions
    • Income tax compliance
    • Indirect tax compliance
    • Governance and control of the above processes

    GCR activities reside in the middle of a broader set of record-to-report (R2R) processes. R2R is the intersection between any company's finance and tax departments and is used to capture, process and store information that is essential to statutory accounting, tax compliance and reporting. Any change to R2R processes, information, finance systems, roles and responsibilities will have a direct impact on GCR processes.

    Helping you meet the new GCR demands

    Fast changing compliance and reporting requirements are more demanding on tax and finance functions today than ever before. So how do you improve control and quality, manage risk, create efficiency and drive value?

    Our market-leading approach combines standard and efficient processes, highly effective tools and an extensive network of local tax and accounting subject matter professionals.

    Related content

  • Building effective supply chains

    As multinational companies seek to reach new markets and compete more effectively in mature markets, they are adapting and differentiating their supply chains. Companies’ operating models need to cater for efficiency and scale in mature markets, while having the flexibility and local ability to support growth in emerging markets. Consequently, driving true shareholder value requires an operating model that combines global and regionally differentiated processes, and integrates these with local striking power and operational excellence.

    Leading companies recognize the need for integrating tax in their business planning and decision processes

    Whether companies seek to enter new markets or drive efficiencies in mature markets, leading companies understand the complexities of the international tax systems. The impact of both direct taxes and indirect taxes needs to be carefully considered and integrated to drive the effectiveness of the operating model while complying with all applicable local and international tax laws and effectively manage all tax risks. Operating model effectiveness is becoming one of the cornerstones of successful competition and differentiation.

    Our approach

    The EY TESCM offering helps ensure you do just that. Our advisory and tax professionals operate as one team to assist our clients with developing and implementing operating model optimization where business needs and requirements are the driver while making sure that tax is an integrated part of the design of the operating model architecture.

  • Managing mobile workforce risk

    In today's globally integrated, tightly regulated and increasingly competitive business environment, one critical success factor stands out: people. It’s no wonder that leading companies are focusing their efforts on:

    • Attracting and retaining the right people
    • Global talent deployment and mobility
    • HR and payroll effectiveness
    • Risk, governance and compliance

    Managing the risks of mobile employees

    While optimizing the competitive advantage of your people has long been a core objective, a more recent set of trends in the tax landscape means that large companies with an internationally mobile workforce are at a higher risk of tax noncompliance and resulting controversy than ever before.

    Fortunately, an increasing number of organizations are currently either planning or embracing a wider process of change for their mobility teams.

    Unintended tax compliance obligations

    These travelers are increasingly creating unintended tax compliance obligations, and the resulting risks are not just personal. They are felt at the corporate level, with the corporate tax function often unaware of the extent of the spreading problem. Tax administrations are becoming increasingly aware of the issue, however, and are very effectively using new technology to identify where a tax obligation has arisen. In a rising tax enforcement landscape, this issue has significant potential to grow.

    Managing these risks should be a burning platform issue for multinational companies.

    Will your tax risks prompt a tax audit?

    What may start as a relatively simple personal income tax compliance issue can quickly create a ripple effect, with risks such as the creation of a permanent establishment, an employment tax audit or the payment of a significant related penalty all occurring at the corporate level.

    Companies, recognizing the spectrum of reputational, personal and financial risks related to tax, are making strong efforts to be compliant. There is an increasing acceptance that such issues are becoming increasingly urgent from both a reputational and a financial perspective.

    How we are helping companies

    Our Human Capital network embeds processes and technology that will help companies to identify and manage short-term business traveler-related risks before they occur. Where controversy has already arisen, our global Tax Controversy network can use our insights into the culture and processes and relationships with each key tax administration to remediate issues. With prior year issues being rapidly unearthed, and with tax administrations focusing on this issue more than ever before, the time to act is now.

    Related content

    EY-Building a new talent management model

    Building a new talent management model

    Businesses are on the brink of a talent crisis. Only a major shift in thinking can help tackle the global talent shortfall.


    Business travelers: assessing tax and immigration risks

    Immigration and tax laws are increasingly aggressive toward business travelers and their companies. Leading companies actively mitigate business travel risks. Do you?

Related content

EY - The shape of things to come

The shape of things to come

As the Chancellor finalises the Business Tax Roadmap, we believe this is not about tax rates, but structuring the system so businesses can operate more effectively.

EY - Trade Watch - December 2015 - Volume 14, Issue 4

TradeWatch, December 2015

Read our global customs and international trade which contains the latest news on customs duties and trade agreements from around the world.

EY - 2014 Global Transfer Pricing Tax Authority Survey

2014 Global Transfer Pricing Tax Authority Survey

Our survey of 50 jurisdictions across the Americas, Asia-Pacific and Europe, confirms that transfer pricing continues to be front of mind for tax authorities and multinationals.

Contact us

Find your nearest Tax contact:


Find out about our Law services.

Tax guides and resources

Global Tax Alerts

Connect with us

Stay connected with us through social media, email alerts or webcasts. Or download our EY Insights app for mobile devices.

Building a business tax blueprint for the UK post-Brexit

EY - Building a business tax blueprint for the UK post-Brexit

Chris Sanger, UK&I Head of Tax Policy and Tim Steel, UK&I Tax Markets Leader, highlight the key findings from our recent survey of over 175 tax and finance professionals on how the tax system affects the UK’s attractiveness post-Brexit.

EY - EU Referendum

What Brexit means for businesses

We explore the implications of the UK’s decision to leave the European Union.