Double Tax Treaties: Beyond 183 Days - Grant Thornton US

Navigating Global Mobility Tax Challenges: Webinar Highlights

At Expat Academy, we know that managing Global Mobility programmes comes with its fair share of complexities – especially when it comes to tax! In our most recent virtual event, led by Richard Tonge at Grant Thornton US, we took a deep dive into one of the most widely discussed topics in the industry: the 183-day rule and its implications for tax relief and compliance.

Key Takeaways:

• Understanding where the 183-day rule fits within the broader landscape of tax relief and mobile employee taxation.
• Practical insights into planning for assignments, business travel, and remote work while staying compliant.
• The complexities of tax treaties and how different national interpretations impact Global Mobility policies.
• The role of economic employer considerations and their effect on tax obligations.
• Common misconceptions around the 183-day rule and how to avoid costly errors.
• Real-world examples of tax challenges faced by global organisations and strategies for mitigating risks.
• The evolving landscape of tax regulations and what Global Mobility professionals need to be aware of in 2025 and beyond.

A key theme of the discussion was the importance of early engagement with tax experts to ensure compliance and reduce unexpected liabilities. Many organisations assume that as long as an employee does not exceed 183 days in a country, no tax obligations arise. However, the reality is far more complex. Factors such as economic employer considerations, the existence of permanent establishments, and varying national interpretations of tax treaties mean that Global Mobility teams need to assess each case individually.

Richard explained how different countries define and enforce the 183-day rule. Some nations count partial days, while others consider calendar years or fiscal years, leading to potential miscalculations. Factors such as transit days, vacations, and unforeseen extensions due to personal emergencies can also impact tax residency status.

The discussion also explored the implications of permanent establishment risk, particularly for employees who regularly sign contracts or conduct business in a foreign jurisdiction. Organisations must be vigilant about how employee activities in different countries might create corporate tax obligations beyond individual income tax considerations.

Whether you attended live or missed out this time, we encourage you to join us for future webinars, where we tackle the industry's most pressing challenges!

Based in the UK? Get more insights from Grant Thornton and other industry experts at our Colloquium on 17th March 2025.

If you're a Global Mobility professional looking to develop your skills and career, get yourself on our GMPD programme! You can access a recording of this webinar, and Grant Thornton webinars on permanent establishment and international social security, in addition to hundreds of other learning resources to supplement your GM knowledge and keep you up-to-date with the latest trends and developments in Global Mobility.