Blick Rothenberg

Our recommendations

Tax policy has a clear role to play in making it easier for employees to be mobile, strong, sustainable growth, and well-designed policies fit for the future.


We recommend:

  • The approach to eliminate double tax via relief through double income tax credits is designed to be more efficient, as there are a number of examples where double tax still does arise.
  • Making pensions more mobile and developing a truly international pension. Increasing the number of tax treaties that provide reciprocal pension relief and providing a universally accepted definition of a pension and it core attributes.
  • Including payroll provisions in the OECD model treaty to reduce double tax and double withholding issues which are on the rise as secondments become shorter in nature. Negative cash flow is a growing issue for this group of executives as payroll withholding in both the home and assignment location is becoming common.
  • Increasing the number of social security tax treaties to avoid double social security tax situations.


We say:

  • Tax advisers should be broad with an understanding of how the corporate, personal and employer tax issues align and fit together - for instance we are seeing the growing importance of this with BEPS and short-term business visitors.
  • Companies should have a strong understanding of how to manage the combined tax, HR and payroll issues relating to internationally mobile executives. For instance, understanding how employees should be valued for transfer pricing and what roles they perform to avoid permanent establishment issues.