Expat PlaybookBest Practices for Sending Employees Abroad

CONTENTS

Introduction 1

Immigration 4

Tax and Payroll 5

Compensation 10

Other Considerations 12

Conclusion 14

Resources 15

About Radius’ Advisory Services Team 17

About Radius 17

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Introduction

Deploying and maintaining talent around the world is a critical priority for multinational companies. Driven by globalization, global mobility is an increasingly important component of maintaining market competitiveness, whether for expanding to a new country, sourcing the right talent or ensuring workforce diversity.

There are myriad reasons why companies choose to send employees overseas on assignment, but employers typically must navigate a common set of challenges with regard to properly managing their expats. Make no mistake: The stakes are high. Employing an expat typically costs two or even three times more than the simple cost of the individual’s home-country salary. Moreover, expat assignments can and do fail, and improper immigration or tax compliance management can lead to serious legal trouble for the employer and/or the employee.

This playbook addresses the most common challenges faced by multinational companies sending employees abroad. Effectively managing a mobile global workforce is highly complex, touching on everything from immigration to taxes, insurance to talent development. Drawing on our vast experience supporting clients that send employees abroad, we have created this document as a roadmap of important questions organizations should answer and sensitivities they should be aware of to successfully deploy a workforce to foreign countries.

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The playbook is organized according to four important themes. Though it would be impossible to give a full, technical account of each, we highlight those issues relevant to most organizations and suggest best practices where appropriate. The four themes are:

1. Immigration

2. Tax and Payroll

3. Compensation

4. Other Considerations

Before addressing these, let’s define what an expat is and suggest a rough taxonomy of expat assignments. For the purposes of this document, an expat is an employee who is sent abroad by his or her employer on a foreign assignment for an extended period of time.

The expat’s length of stay in the host country is often a critical determinant of his or her immigration status, compensation, taxes and treatment under company policy, among other factors. Thus, the most salient organizing principle for expat assignments is determined by assignment length. Here are five common types of expat assignments.

› Business visitor assignments: Typically last less than six months and can often be treated as a regular business trip, with reduced consideration for issues such as immigration and taxation (although the details of each assignment, including country requirements, must be reviewed).

› Commuter assignments: Frequently crossing jurisdictions (e.g., between the United States and Canada); how these expats are managed will largely be determined by the amount of time they spend in the host country and the activities being performed.

› Short- and medium-term assignments: Last anywhere from six months to two years and will require full consideration of immigration, taxation and other issues.

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› Long-term assignments: Usually last more than two years and require full consideration of immigration, taxation and other issues.

› Permanent assignments: These are “one way” relocations, and the expat is expected to remain in the host country permanently or for the foreseeable future. Often the expat’s employment contract and compensation treatment will be structured like those of locally hired employees, but with some additional payments to cover the initial relocation.

Understanding the composition of your expatriate workforce and adopting policies to manage them effectively begins by ensuring you understand how long each employee plans to be or has been outside the home country and where each employee has been or will be located. A common theme throughout this playbook is the importance of developing expat policies that are appropriate to different types of assignments and implementing a system to administer and track expats. Taking these steps will help ensure that you are being consistent in your treatment of each employee, aware of and proactively addressing key questions that may arise from employees and other company stakeholders, and properly managing expatriates according to home- and host-country obligations to avoid costly errors.

It is advisable, then, that employers adopt and adhere to a comprehensive global mobility policy. The policy should address the key considerations discussed throughout this document, including incentives for accepting a foreign role, logistical support, local housing allowances, family support and tax considerations, among many others. Adopting and adhering to a well-structured policy with clear guidelines will help provide for a consistent and transparent approach across a potentially diverse expat population, removing uncertainty and reassuring your employees that you are in control.

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Immigration

Ensuring that an expat is legally permitted to work in a host country is an essential preliminary step to any deployment. Failing to comply with applicable work and residency requirements can result in disruption to the business and reputational damage, as well as considerable inconvenience to the employee. Permission to work in a host country can never be assumed, and securing proper immigration status should always be considered “step one” in the expat process. Failing to meet immigration requirements can be an immovable barrier to expatriating an employee. Proper authorization should always be sought early in the expat assignment planning process and secured prior to the expatriate’s travel.

It is critical that the immigration laws of a country be understood at the outset of an expat assignment. The length of stay, nature of work and whether or not the employer has a local legal presence are all likely to influence the steps required to ensure that an expat is legally permitted to work in the host country. For example, whereas short-term and commuter expats can often work in a host country without special authorization (provided they meet the criteria for a business visitor), long-term expats often need work permits. However, care still must be taken with short-term business visitors, as some countries require an entry visa or other permissions for those visitor types. It is vital that the employer researches the requirements of the target country prior to each assignment, regardless of the length of stay.

It’s worth reiterating that each jurisdiction’s immigration laws vary. China is an excellent example of a country with a complex immigration landscape. Short-term expats must apply for a so-called F visa, which permits them to work in the country for up to six months. Long-term expats must apply for a so-called Z visa. No matter which visa the expat holds, if they stay longer than 30 days they must apply for a residency permit. These permits, which are essentially another type of visa, are typically valid for a year and may be renewed.

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Often, work permits require the sponsorship of a local entity. As a result, it is important for the employer to determine whether it has a qualifying local corporate presence in the host country and, if not, to establish one or use another locally permissible means of obtaining a permit, such as partnering with an established host-country entity such as a partner, vendor or customer. In some countries, however, and in exceptional cases, a local entity is not required. For example, in Australia, non-resident employers (e.g., US employers) are able to deploy an expat to Australia where the US company itself registers as a sponsor in Australia on a “non-resident” basis and obtains the work permit through this registration. This is, however, unusual.

As the case studies of China and Australia demonstrate, the inherent complexities of so many countries’ immigration laws can be difficult to understand and comply with. Properly securing authorizations is usually an unavoidable, lengthy and intensive process, particularly for any entities that are newly created in-country.

Tax and Payroll

When you send employees to work in other countries, you often expose them to complex tax considerations. Depending on a number of factors, including the countries in question, the length of assignment and the types of compensation, expats can incur higher taxes and double taxation (and potentially social security) across multiple countries. As the employer, it is important to ensure that you thoroughly understand local tax and social security

“Permission to work in a host country can never be assumed, and securing proper immigration status should always be considered ‘step one’ in the expat process.”

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obligations, which in turn will enable you to make critical decisions that will affect the tax status and reporting obligations of both the company and the employee. Failing to do so can result in tax violations. It may also lead to reluctance on the part of your employees to accept a foreign posting where they perceive they may be worse off from a tax standpoint, or if they feel your company hasn’t been transparent about their tax obligations up front.

The tax and social security laws and treaties of both the home and host countries will determine how an expat employee will be taxed when on assignment, together with the length of the assignment, which is a key taxation trigger. As a general rule, when an expatriate spends less than 183 days in any 12-month period in a country, it is usually possible to avoid triggering income tax and payroll withholding obligations in that country.

However, employers must tread carefully even when managing short-term assignments, as related exemptions are conditional. First and foremost, no costs related to the expatriate may be paid for or borne by a permanent establishment (i.e., some form of local entity) in the host country. It’s worth repeating that our example here is a general one and by no means covers all situations. Not all countries have double tax treaties, for instance, and your target country’s domestic legislation may specify that a different number of days in-country triggers tax obligations (or a different period over which days in-country must be counted).

In all cases it is vital to understand the specific tax triggers of the countries involved prior to sending an employee abroad. In addition, it is essential to accurately track and record employees’ work days spent in all countries, typically during any 12-month period though in some cases for longer than that. Keep in mind that pre-deployment trips to a host country must be counted towards a tax-trigger threshold.

An employer must also address two primary tax-related questions before deploying workers overseas. First, you must determine whether or not the company intends to protect expatriated employees against potential increases in their personal tax burdens (or recover any tax savings they may realize) while on assignment. Second, you must consider a payroll structure to fulfill withholding tax and social security obligations in the home and host countries, including remitting taxes, social security and the expatriate’s net pay and allowances.

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Some employers choose not to protect their expatriated employees against the vagaries of international tax laws, effectively exposing them to either higher or lower taxes without remediation. This approach is called “laissez-faire.” Laissez-faire expat tax policies may seem a logical enough approach in today’s belt-tightening global economy, but you should be aware that such policies are often accompanied by long-term costs that may be hard to predict and quantify. For example, a laissez-faire expat policy may be seen by employees as uncompetitive compared with other employers’ policies — and you should keep in mind that expatriate employees can and do talk! This may lead to reduced employee engagement and increased turnover. Even more importantly, a laissez-faire policy may result in the employer having difficulty filling important positions abroad in relatively high tax jurisdictions.

Most of our clients offer some sort of tax relief and assistance to their expatriate employees, either in the form of full tax equalization or tax protection on specific items. This helps position them as fair and reasonable employers.

Tax equalization ensures that an expat employee’s take-home pay on non-assignment income will be the same as it would have been had they remained at home. Should an employee’s tax liability increase following an assignment, the employer pays the difference and the employee’s effective tax burden does not change. Conversely, if the expat’s tax liability decreases, under a tax-equalization policy the employee does not benefit from the tax reduction and continues to receive the same net income that they would have received had they remained at home. Effectively, then, the tax savings are internalized by the company and can be seen as an offset to the other costs of the assignment, such as expatriate benefits and allowances.

Tax equalization is in short a fully transparent and easily understandable system that provides expatriates with complete comfort that their overall net income position will be unaffected by an assignment. It essentially makes the expatriate employee “tax blind” or “tax neutral.”

“It is vital to understand the specific tax triggers of the countries involved prior to sending an employee abroad.”

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Tax protection is similar to tax equalization. However, the policy may be less comprehensive and address only certain compensation items. In addition, any tax savings realized are generally retained by the employee, not by the company.

Whether or not the expatriated employee is insulated from local taxes (and social security where applicable), the onus is still on you, the employer, to properly withhold any applicable income taxes and social security and remit those liabilities to the relevant authorities. Various payroll options are available to pay expatriated employees and comply with home- and host-country tax laws. The best approach in any particular situation will depend on a number of factors, including: the host countries involved and related obligations; the tax reimbursement method that applies to the compensation structure; the expat’s obligations in the home country; and administrative burdens.

Here are some examples of typical expat payroll options:

› Using a host-country payroll.

› Paying the employee from a “split payroll,” in which some compensation passes through the home-country payroll and some through the host-country payroll.

› Paying the employee from the home-country payroll while establishing a “shadow payroll” in the host country, from which taxes can be calculated and paid to host-country tax authorities.

The most important task when structuring an expat payroll solution is ensuring that all of the expat’s relevant income is reported and taxed in the correct countries, while striving for transparency and administrative efficiency. This can be a real challenge, particularly with a split-payroll arrangement. In such situations, you may have to make manual adjustments each pay period to ensure the appropriate amount of compensation is being reported in both the home and host countries. This adds complexity, time and cost to the payroll process, and

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we generally do not recommend any form of split payroll arrangement unless there is some overriding compliance obligation that requires it.

The last option listed above — that of a shadow payroll — is typically the preferred means by which a tax equalization policy is administered through a payroll. As the name implies, a shadow payroll does not actually pay the employee but is merely the mechanism by which taxes are calculated, reported and paid to host-country tax authorities on a timely basis. It enables the employee to remain on a home-country payroll while the employer pays for all taxes arising from the shadow payroll.

Depending on the home and host countries involved, a tax equalization policy (and attendant payroll arrangements) may need to address social security contributions in addition to income taxes. The employer’s and employee’s respective obligations vis-à-vis social security payments vary by the home and host country as well as by the length of the assignment. In some cases, the home and host countries may have in place agreements to avoid double withholding of social security funds. Under such agreements — called totalization agreements, reciprocal agreements or double contribution conventions — the expat is only required to participate in one of the two countries’ social security programs. In the absence of such agreements, the employee may be required to pay social security taxes in both countries. Where tax equalization or protection applies, these costs are met by the employer, so it is essential to understand and plan in advance for such costs.

Finally, it is worth considering how best to help employees navigate their new tax environment. Filing taxes in their home country is often difficult, but doing so in a foreign system with additional cross-border complexity is enough to overwhelm even typically self-sufficient tax filers. In the interest of maintaining a happy, productive and tax-compliant workforce, employers generally pay for expatriated employees to receive tax-planning support, arrival and departure tax briefings in their host and home countries, and assistance preparing and filing their home- and host-country tax returns.

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Compensation

Traditionally, employers have paid expats their home salary, with an adjustment to reflect the cost of living in the country to which they were assigned. In the past several years, however, organizations have responded to downward cost pressure, the globalization of the labor force and other trends by increasingly adopting a more varied set of approaches to structuring expat compensation. There is no single best answer, but selecting the right compensation scheme for your organization and situation is important to properly incentivize assignees, ensure pay equity, preserve workforce mobility and control costs.

The most fundamental expat compensation decision an employer must make is whether to adopt a home-based or host-based approach. In selecting between the two approaches

— and the many permutations associated with them — a number of factors should be considered. These factors include: the organization’s compensation philosophy; the length and attractiveness of the assignment; the home country and host country in question; and the tax implications for both the employer and employee.

Notwithstanding recent trends, the home-based approach to expat compensation remains prevalent. Under this system, expats continue to receive the salary they received in their home country, often in addition to assignment incentives and allowances for expenses associated with relocating. If the new country has a higher cost of living, employers can also provide compensation adjustments to ensure that their expats’ purchasing power does not diminish.

“The most fundamental expat compensation decision an employer must make is whether to adopt a home-based or host-based approach.”

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There are, of course, significant variations to home-based compensation structuring. For example, if an expat assignment is long, allowances for higher costs of living may be phased out gradually over an adjustment period of several years. In addition, if an assignment becomes permanent, employers often transition expats to host-based compensation plans. It is important to develop policies for such situations and to discuss them in advance of the assignment with the employee to set expectations.

Under the host-based approach to compensation, expats’ pay is determined based on the local labor market. Typically, assignment incentive and allowance compensation is more limited under this scheme, which explains its growing attractiveness to cost-conscious organizations.

Employers must carefully evaluate the implications of both approaches in light of specific countries and assignments. Though host-based compensation is often more economical, it is not always so. Take, for example, a hypothetical Mumbai-based employee of an Indian firm being assigned to Geneva, Switzerland. Under the host-based approach, the employee would likely benefit from a significant increase in base compensation. Although this would be perfectly appropriate given the significantly higher cost of living in Geneva, it presents difficulty should the firm transfer the employee back to Mumbai. A salary reduction would hardly be a welcome prospect for the employee, but, then again, paying a Geneva wage in Mumbai would not be economically feasible. In this case, keeping the employee on his or her home salary and providing a cost-of-living allowance or adjustment would likely represent the best long-term solution.

The logistics of moving to a new country for months or even years can be daunting. Employers often support their expats in moving and establishing themselves and their families by contracting with a relocation firm. The services provided by such firms vary, but they often include assistance with travel, temporary housing and assistance in finding a new home or apartment, support in selecting a school for the expat’s children, and help

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navigating local administrative matters such as opening a bank account. Such support may also continue after the transition period; for example, some employers will pay for the expat to return home several times per year or for the expat’s children to attend an international school. Deciding whether and how to provide such support requires advance consideration of budget impact and the potential effects of a foreign assignment on the expat employee in question. Ultimately, providing relocation and ongoing assistance will likely advance the mutual goals of the employer and expat employee — that is, a smooth transition and successful assignment.

It is important to consider taxes when determining how to compensate employees. Decisions about tax equalization and protection will often dictate how compensation must be structured — both policies typically necessitate a home-based approach. In addition, supplemental compensation (such as a moving allowance or tuition for a dependent’s local schooling) is often taxable. The tax implications for the employer must also be taken into account. Not only may the employer be required to pay taxes on the supplemental compensation it is providing to its expat employee (assuming a tax equalization or protection policy), but it may also be tax-advantaged or disadvantaged from a corporate tax perspective depending on how it structures compensation and payroll.

Other Considerations

There are, of course, many other items to consider when sending expats on assignment. Expat assignments can affect everything from corporate structuring and intercompany cost/service agreements to employee health and safety policies. Systematically and thoughtfully addressing these issues in advance is important to avoid unwelcome surprises and to position expats for success.

The structure of the expat’s compensation and associated relocation expenses and the logistics of payroll can have significant accounting and tax-liability implications. It is important to consider, for example, how intercompany cost agreements provide for cost sharing across entities . In some instances, it may be optimal from a corporate tax perspective to split the costs of the expat between home-country and host-country entities. Alternatively, and depending on the

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host country, length of stay and other factors, it may not make sense to recharge the cost of the expat. In short, you’ll need to carefully consider the terms of any intercompany agreements when making decisions about expat compensation, taxation and payroll.

Ensuring that expats and their families have proper insurance coverage is another necessity. Unlike home-country assignments in which insurance is often quite straightforward, expat assignments must often be supported by a wide a variety of insurance products such as evacuation insurance, repatriation insurance, and even kidnap and ransom insurance. It is also advisable to ensure that your organization’s commercial liability insurance coverage extends to the expat on assignment.

Employers are responsible for the safety of their employees, particularly when they have sent them abroad on behalf of the company. For organizational, reputational and even legal reasons, employers must take seriously the duty of care they owe to their employees. To do this, employers must take reasonable steps to protect employees by understanding the risks of specific assignment areas and by having in place monitoring programs and contingency plans.

In addition, it may be beneficial to implement formal practices or systems to enable your expat employees to succeed. These may include cultural orientation programs and mental health therapy offerings for family members, who can feel isolated as a result of an assignment. Not only will such offerings help you avoid the costs and disruption of “failed” deployments, they could also make overseas deployments more desirable and help your company develop and retain talent in an increasingly competitive global employment marketplace.

Finally, you need to consider repatriating your assignees, including related travel and moving expenses and any outstanding payments in the host country such as those related to housing. The terms of any expat assignment should be clear not only about host-county activities, roles

“Expat assignments can affect everything from corporate structuring and intercompany agreements to employee health and safety policies.”

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and compensation, but also about the nature of employment when the assignee returns home. Will he or she be guaranteed a position, and if so how will repatriation affect the employee’s compensation and role, including title? Depending on the length and nature of the assignment, many employers offer reintegration assistance. Coming back to one’s home country after a prolonged period abroad can be a surprisingly difficult, and isolating, experience.

Repatriation is an often-overlooked aspect of expatriate assignments, in part because so much preparation must be devoted to the details of the initial relocation. But failure to properly prepare for the effects of repatriation can be costly, both in terms of overlooked expenditures and potential employee disengagement.

Conclusion

Sending employees abroad can be an effective way for your organization to expand internationally, revitalize moribund operations or simply test new markets. Overseas assignments can also provide rich and enjoyable life and career experiences for the expats themselves. Achieving these mutual benefits requires careful preparation, clear communication with the expat and ongoing, active monitoring. Above all, the costs of such assignments should be well understood by all parties; policies and individual packages are created in part to avoid unpleasant budgetary shocks down the line.

As outlined in this playbook, organizations must ensure that their expat employees are legally able to work in the host country, that they are being compensated appropriately, that required taxes and social security are being withheld, and that they (and, if applicable, their families) are positioned to flourish in their new homes. Executing against these imperatives is best done with a systematized approach that takes into account the circumstances of each assignment. With this accomplished, your expat employees will be able to do their jobs effectively and should be sufficiently engaged to remain with the company for a long time.

No one ever claimed sending expats on assignment is inexpensive. However with proper advanced planning and the implementation of some key best practices, you can help your company fully realize the ample rewards that come with sending employees abroad.

“For organizational, reputational and even legal reasons, employers must take seriously the duty of care they owe to their employees.”

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Resources

Blog Articles

“You Need to Beware of Short-Term Expat Assignments,” www.radiusworldwide.com/blog/2016/3/you-need-beware-short-term-expat-assignments

“When Hypothetical Taxes Are Real: Compensation Policies for Expat Employees,” www.radiusworldwide.com/blog/2015/4/when-hypothetical-taxes-are-real-compensation-policies-expat-employees

“Future of the Global Workplace: Keeping Pace with Changing Immigration Laws,” www.radiusworldwide.com/blog/2015/10/future-global-workplace-keeping-pace-changing-immigration-laws

“Duty of Care: Have a Risk Management System in Place Before Sending Employees into Harm’s Way,” www.radiusworldwide.com/blog/2014/5/duty-care-have-risk-management-system-place-sending-employees-harm-s-way

“Expat Tax Focus: Sending a US Employee to Germany,” www.radiusworldwide.com/blog/2015/8/expat-tax-focus-sending-us-employee-germany-part-1-2

“Complying With China’s New Visa Requirements for Short-Term Workers,” www.radiusworldwide.com/blog/2015/5/complying-china-s-new-visa-requirements-short-term-workers

“An American Expat in Brazil,” www.radiusworldwide.com/blog/2015/2/american-expat-brazil-part-1-3

eBooks

Winning Globally: A Playbook for International Expansion Teams, www.radiusworldwide.com/knowledge/resources/ebook-winning-globally-all-chapters, see especially Chapter 8,

“Transfer Expats or Hire Locals?”

Global HR Playbook, www.radiusworldwide.com/knowledge/resources/global-hr-playbook

Budgeting for International Expansion Playbook, www.radiusworldwide.com/knowledge/resources/international-budget-playbook

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Resources

Webinars

“Expats: What to Consider Before Sending Your Employees Overseas,” www.radiusworldwide.com/content/confirmation-webinar-recording-expats-may-2016

“Global Mobility: The Cost of Host-Based Compensation Solutions,” www.radiusworldwide.com/content/webinar-recording-webinar-global-mobility-cost-host-based-solutions

“Global Payroll: Are You Meeting Your Obligations?” www.radiusworldwide.com/knowledge/events/webinar-global-payroll-proformative-march-2016

“Duty of Care: Protecting Your People and Minimizing Organizational Risk,” www.radiusworldwide.com/knowledge/events/duty-care

Case Study

Contently: Advanced Expat Planning With a Trusted Partner, www.radiusworldwide.com/knowledge/case-studies/case-study-contently

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About Radius’ Advisory Services Team

If you’re concerned about protecting your company and its employees from the risks of sending expats on assignment, or if you’re facing other international challenges, Radius’ seasoned advisory team can help you understand your options and recommend practical, compliant solutions.

Our advisors are senior practitioners with real-world experience in international expansion and operations. They include former Big Four international consultants, CPAs, auditors, lawyers, international HR experts, business school graduates and tax specialists. Many have broad expertise in functional and geographic areas, and many have niche specializations in subjects such as immigration and HR obligations, direct and indirect taxes, transfer pricing, data protection and anti-bribery legislation.

Let us help ensure that your international operations are in compliance with all applicable laws, that you’ve completed all necessary registrations, and that you’ve developed and implemented optimal policies and procedures to reduce risk and gain a competitive advantage.

For information on how Radius’ experts can help, contact us.

About Radius

Radius helps companies expand and win globally. Clients from startups to larger multinationals take advantage of Radius’ international accounting, finance, banking, tax, HR, legal and compliance support to simplify their core operations, reduce their risk exposure and improve the management and control of their overseas businesses.

Radius delivers support and expertise through managed services, advisory services and OverseasConnect, our integrated cloud-based software platform, to create solutions that meet the needs of over 600 clients operating in 110 countries around the world. Headquartered in Boston with offices in the UK, Brazil, China, India, Japan and Singapore and over 800 employees worldwide, we are the global growth experts. For more information, please visit www.radiusworldwide.com.

US Tel: +1 888 881 6576UK Tel: +44 (0) 203 005 5518Email: sales@radiusww.com

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This bulletin is written and provided for general information purposes only, and is not intended to address the circumstances of any particular individual or entity. The information contained herein is subject to change, and is not intended as and should not be used as a substitute for taking professional advice. We do not provide any representation or warranty (express or implied) as to the accuracy or completeness of the information contained herein, and to the extent permitted by law, Radius does not accept or assume any liability from the use of this bulletin. Any tax advice contained herein (including in any attachments and enclosures) is not intended to and should not be construed as an opinion. No one should act, or refrain to act, in reliance on the information contained in this bulletin without seeking professional advice after a thorough examination of the particular situation. If you have any questions about this information, please contact Radius.

Last revised August 12, 2016