FS Transfer Pricing Decoded

The first episode of the series discusses a topic which many organisations are increasingly having to assess and manage from a tax perspective – staff working from outside of their country of employment. 

So when can such movement of staff create a permanent establishment (PE) for corporate tax purposes and what are some of the key personal tax consequences to think about? In this episode listen to Stephen, Louise, Giles and Murray; where they discuss these points through case studies.

Case study questions:

Example 1: A middle office employee, employed by a French entity, is forced to work remotely in the UK. - What are the basic PE principles and personal tax consequences to consider? - What changes if they now choose to work in the UK? - Would it matter if their employer gave them a home work contract and for a longer period? - What if colleagues from other departments were working from home in the same country?

Example 2: A sales person works remotely in their home before relocating to the country of their new employer. - What are the PE considerations in this example? - What happens if they adopt a split working model working in both countries?

Profit Attribution – if transfer pricing principles are followed, can the PE considerations be ignored?