The 2017 Global HR conference

1. The 2017 Global HR conference International Assignments & Business Traveller Update Andrew Bailey, Head of Global Expatriate Services - BDO LLP 6 February 2017

2. The 2017 Global HR Conference – 6 February 2017

3. 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 The 2017 Global HR Conference – 6 February 2017

4. 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

5. 2016 BDO/santafe 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

6. Most frequent sending and receiving countries • 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) The 2017 Global HR Conference – 6 February 2017

7. business travellers • Treaty exemption • 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 The 2017 Global HR Conference – 6 February 2017

8. The 2017 Global HR Conference – 6 February 2017

9. The 2017 Global HR Conference – 6 February 2017

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11. Source https://www.gov.uk/hmrc-internal-manuals/paye-manual/paye82000 The 2017 Global HR Conference – 6 February 2017

12. business travellers • Short Term Business Travellers • 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 The 2017 Global HR Conference – 6 February 2017

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14. 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

15. 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 The 2017 Global HR Conference – 6 February 2017

16. 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

17. BIOGRAPHY • Andrew Bailey • Head of Global Expatriate Services • andrew.bailey@bdo.co.uk • Direct: +44 (0) 20 7893 2946 • Mobile: +44(0) 783 367 0859 • 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. The 2017 Global HR Conference – 6 February 2017