Global Tax Trends: Impact and Management
Speaking With You Today
Gwen Sakponou
Tax Solutions
Manager
Equus Software
John Neely
Senior Manager
Grant Thornton
Richard Tonge
Principal
Grant Thornton
CONTEXT
OBJECTIVES
OUTCOMES
Key Learnings
Changes in tax legislation for key countries.
Understand the impact of those changes on
your global mobility programs.
Better equipped to make informed decisions
using Equus’ solutions.
1
2
3
Agenda
Global Tax Update
Case Study: Focus on India
Experience Post TCJA
Global Tax Update
China Tax Reform
Domicile clarified and new
'six year rule' for long-term
expats
Phase out of tax efficient
expat benefits from 2022
Phase out of preferential
tax treatment on incentive
compensation
Introduction of new tax
deductible expenses for
locals and expats
What are the takeaways from the new regulations?
China Tax Reform
What is the impact?
Payroll complexity increases for expats
and domestic employees
Tax return process allows for deductions,
residency review and refunds
Phase out of preferential treatment
challenges compensation arrangements
Increased risk for payroll administration
Falling tax cost for certain assignees and
business travelers
Incentive compensation remains beneficial
if structured effectively
Broader range of deductions to reduce tax
cost to Employee and Employer
Uncertainty from 2022 and a response to
economic conditions?
Administrative Cost
China Tax Reform
Cost Estimate Trends
2015 2018
Where are they coming from?
Focus on Brexit : Expert View
No Deal
- Brexit on 6/1/19 or
10/31/19
- Existing Regulations
and A1s cease to
apply
- Reversion to bilateral
agreements
Remain
- Existing regulations
continue
- Existing and new A1
certificates
- Up to 5 years home
country coverage
Deal
- EU Regulations could
continue through
transition to 12/31/20
- Existing A1 certificates
remain valid
- New arrangements
post-Brexit?
X
Focus on Brexit:
Impact for US MNC’s operating within EU
Increased social tax cost of
mobility from UK operations
Mobility candidates and
planning challenges
Increased business
administration for potential
new arrangements
Agreement gaps leading to
potential dual contributions
Contributions stop after 12
months – cost saving or
disincentive?
Comparing Social Security Contributions on USD 200k
• Assuming UK-FR agreement
no longer in force
• Dual contributions required
Focus on Brexit
Comparative cost of social security on 120K in the EU
0
10,000
20,000
30,000
40,000
50,000
60,000
70,000
InUSD
Employer Social Tax Employee Social Tax
Social Taxes: Widening the Net
China
EU
India
Beyond Shanghai Totalization Networks
Impact of Brexit beyond immigration and trade
Supreme Court Rulings increases income subject to contributions
Uncapped
contributions for 'international workers'
15,000
rupees contribution limit for domestic employees
12%
employer and employee rates
24%
where employee meets employer burden too
Historic split of compensation between salary, 'special
allowance' and other allowances and perquisites.
Compensation 'paid uniformly and universally by an
employer to its employees'
Broad impact on Cost to Company (CTC) for both domestic
and international employees
'International workers' have uncapped contributions. No
totalization agreement with U.S.
Does not apply to variable incentive compensation such as
bonus and equity
Focus on India
Supreme Court Ruling
14
Case Study:
Focus on India
Case Study: Focus on India
Capped or unlimited contributions?
Status Rate Outbound Inbound
Agreement 24% Cap None
No Agreement 24% Unlimited Unlimited
List of Agreements
Australia Austria
Belgium Brazil
Canada Czech
Republic
Denmark Finland
France Germany
Hungary Japan
Korea Luxembourg
Netherlands Norway
Portugal Sweden
Switzerland
No agreement yet with the United States
Case Study: Focus on India
Comparing Social Tax Costs on USD 200K
• $23K difference between 2
scenarios
• For a population size of
100 amounts to $2.3M
Case Study: Focus on India
Managing the Costs – Equus Solution
India Tax Position
• Enter CoC Salary Cap %
• Enter % to be multiplied by
base salary to determine EPF
wage ceiling
• Employee must have a
certificate of coverage to be
eligible
Case Study: Focus on India
Cost Estimate Trends
India Outbounds: US vs Canada
United States,
96%
United States,
54%
Canada,
4%
Canada,
46%
2015 2018
Experience Post TCJA
Increased costs of Long-Term Assignments
Assignment Allowances
Shift to Short Term
Experience Post TCJA
U.S. Tax Reform – Mobility Impacts
Moving Expense Deduction
Experience Post TCJA
U.S. Tax Reform – Mobility Impacts
Moving Expense Deduction: Illustrate increased cost of long-term assignments
Pre TCJA (2017 Law) TCJA (2018 Law)
100 employees * $6K = $600K
Personal Exemptions Eliminated
Deductions
Withholding complications
Experience Post TCJA
U.S. Tax Reform – Mobility Impacts
Adjustments to Taxable Income
Tax on Controlled Foreign Corporations
Increased Tax Compliance Costs
Policy Impact
Experience Post TCJA
U.S. Tax Reform – Mobility Impacts
Global Intangible Low-Taxed Income (GILTI)
Experience Post TCJA
U.S. Tax Reform Expert View – What did we learn?
More Experience Based Assignments
Assignment Allowance Approach
More Short Term Assignments
Experience Post TCJA
Cost Estimate Trends
Type of moves Average Salary
1
2
3
Wrap-up
Global Tax Update
Case Study: Focus on India
Experience Post TCJA
Where Next?
Empowering
Employees with
Flexibility, Choice &
Self-Service Tools
2:10 – 2:55
From Concept to
Design –
Redesigning your
Initiations Process
2:10 -2:55
Strategic Practical
Questions?
Don’t forget to leave your feedback in the app!
DENVER (HQ)
1809 Blake Street, 200
Denver, CO 80202
+1 (303) 292-4200
www.equusoft.com
DALLAS
5601 Granite Parkway
Suite 260
Plano, TX 75024
+1 (214) 989-4339
UNITED KINGDOM
3rd Floor
1 Norton Folgate
London, E1 6DB
+44 (0)20 3540 6248
MANILLA
Level 5, Gateway Tower
Araneta Center, Cubao
Barangay Socorro, Quezon City
Philippines 1109
LISBON
Avenida da Liberdade
N°245, 4A, Suite 420
1250-143 Lisbon
Portugal

Equus AMR Tax Update

  • 1.
    Global Tax Trends:Impact and Management
  • 2.
    Speaking With YouToday Gwen Sakponou Tax Solutions Manager Equus Software John Neely Senior Manager Grant Thornton Richard Tonge Principal Grant Thornton
  • 3.
    CONTEXT OBJECTIVES OUTCOMES Key Learnings Changes intax legislation for key countries. Understand the impact of those changes on your global mobility programs. Better equipped to make informed decisions using Equus’ solutions.
  • 4.
    1 2 3 Agenda Global Tax Update CaseStudy: Focus on India Experience Post TCJA
  • 5.
  • 6.
    China Tax Reform Domicileclarified and new 'six year rule' for long-term expats Phase out of tax efficient expat benefits from 2022 Phase out of preferential tax treatment on incentive compensation Introduction of new tax deductible expenses for locals and expats What are the takeaways from the new regulations?
  • 7.
    China Tax Reform Whatis the impact? Payroll complexity increases for expats and domestic employees Tax return process allows for deductions, residency review and refunds Phase out of preferential treatment challenges compensation arrangements Increased risk for payroll administration Falling tax cost for certain assignees and business travelers Incentive compensation remains beneficial if structured effectively Broader range of deductions to reduce tax cost to Employee and Employer Uncertainty from 2022 and a response to economic conditions? Administrative Cost
  • 8.
    China Tax Reform CostEstimate Trends 2015 2018 Where are they coming from?
  • 9.
    Focus on Brexit: Expert View No Deal - Brexit on 6/1/19 or 10/31/19 - Existing Regulations and A1s cease to apply - Reversion to bilateral agreements Remain - Existing regulations continue - Existing and new A1 certificates - Up to 5 years home country coverage Deal - EU Regulations could continue through transition to 12/31/20 - Existing A1 certificates remain valid - New arrangements post-Brexit? X
  • 10.
    Focus on Brexit: Impactfor US MNC’s operating within EU Increased social tax cost of mobility from UK operations Mobility candidates and planning challenges Increased business administration for potential new arrangements Agreement gaps leading to potential dual contributions Contributions stop after 12 months – cost saving or disincentive?
  • 11.
    Comparing Social SecurityContributions on USD 200k • Assuming UK-FR agreement no longer in force • Dual contributions required
  • 12.
    Focus on Brexit Comparativecost of social security on 120K in the EU 0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 InUSD Employer Social Tax Employee Social Tax
  • 13.
    Social Taxes: Wideningthe Net China EU India Beyond Shanghai Totalization Networks Impact of Brexit beyond immigration and trade Supreme Court Rulings increases income subject to contributions
  • 14.
    Uncapped contributions for 'internationalworkers' 15,000 rupees contribution limit for domestic employees 12% employer and employee rates 24% where employee meets employer burden too Historic split of compensation between salary, 'special allowance' and other allowances and perquisites. Compensation 'paid uniformly and universally by an employer to its employees' Broad impact on Cost to Company (CTC) for both domestic and international employees 'International workers' have uncapped contributions. No totalization agreement with U.S. Does not apply to variable incentive compensation such as bonus and equity Focus on India Supreme Court Ruling 14
  • 15.
  • 16.
    Case Study: Focuson India Capped or unlimited contributions? Status Rate Outbound Inbound Agreement 24% Cap None No Agreement 24% Unlimited Unlimited List of Agreements Australia Austria Belgium Brazil Canada Czech Republic Denmark Finland France Germany Hungary Japan Korea Luxembourg Netherlands Norway Portugal Sweden Switzerland No agreement yet with the United States
  • 17.
    Case Study: Focuson India Comparing Social Tax Costs on USD 200K • $23K difference between 2 scenarios • For a population size of 100 amounts to $2.3M
  • 18.
    Case Study: Focuson India Managing the Costs – Equus Solution India Tax Position • Enter CoC Salary Cap % • Enter % to be multiplied by base salary to determine EPF wage ceiling • Employee must have a certificate of coverage to be eligible
  • 19.
    Case Study: Focuson India Cost Estimate Trends India Outbounds: US vs Canada United States, 96% United States, 54% Canada, 4% Canada, 46% 2015 2018
  • 20.
  • 21.
    Increased costs ofLong-Term Assignments Assignment Allowances Shift to Short Term Experience Post TCJA U.S. Tax Reform – Mobility Impacts Moving Expense Deduction
  • 22.
    Experience Post TCJA U.S.Tax Reform – Mobility Impacts Moving Expense Deduction: Illustrate increased cost of long-term assignments Pre TCJA (2017 Law) TCJA (2018 Law) 100 employees * $6K = $600K
  • 23.
    Personal Exemptions Eliminated Deductions Withholdingcomplications Experience Post TCJA U.S. Tax Reform – Mobility Impacts Adjustments to Taxable Income
  • 24.
    Tax on ControlledForeign Corporations Increased Tax Compliance Costs Policy Impact Experience Post TCJA U.S. Tax Reform – Mobility Impacts Global Intangible Low-Taxed Income (GILTI)
  • 25.
    Experience Post TCJA U.S.Tax Reform Expert View – What did we learn? More Experience Based Assignments Assignment Allowance Approach More Short Term Assignments
  • 26.
    Experience Post TCJA CostEstimate Trends Type of moves Average Salary
  • 27.
    1 2 3 Wrap-up Global Tax Update CaseStudy: Focus on India Experience Post TCJA
  • 28.
    Where Next? Empowering Employees with Flexibility,Choice & Self-Service Tools 2:10 – 2:55 From Concept to Design – Redesigning your Initiations Process 2:10 -2:55 Strategic Practical
  • 29.
    Questions? Don’t forget toleave your feedback in the app!
  • 30.
    DENVER (HQ) 1809 BlakeStreet, 200 Denver, CO 80202 +1 (303) 292-4200 www.equusoft.com DALLAS 5601 Granite Parkway Suite 260 Plano, TX 75024 +1 (214) 989-4339 UNITED KINGDOM 3rd Floor 1 Norton Folgate London, E1 6DB +44 (0)20 3540 6248 MANILLA Level 5, Gateway Tower Araneta Center, Cubao Barangay Socorro, Quezon City Philippines 1109 LISBON Avenida da Liberdade N°245, 4A, Suite 420 1250-143 Lisbon Portugal

Editor's Notes