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Tax Implications on Cross Border Employee Mobility – for HR Professionals

Mitigating Corporate and Individual Tax Risks

Expert Speaker Sivakumar Saravan

$642.00 (including GST)



As economies become borderless, tax authorities are increasing their scrutiny on cross-border movement of employees as a means to levy taxes on foreign entities and foreigners having an economic relationship in their jurisdictions. This can lead to double taxation or even costly penalties for non-compliance. Hence, learning how to interpret and apply tax treaty provisions is critical to better manage both employer and employee tax costs.

This workshop is part of our Corporate Practice Series designed specifically for HR professionals to address key corporate and individual tax implications relating to employees cross border assignments; which could either be a result of employees being seconded or deployed to undertake projects on behalf of the company. This event will equip you with best practices and planning tips to mitigate tax risks and avoid costly penalties arising from cross border employee mobility. 

What You Will Learn  

At the end of this workshop, you will:

  • Be aware of key cross border employee mobility tax issues that will impact the HR Budget
  • Overcome common corporate and individual tax pitfalls by learning how to implement a risk management framework
  • Apply best practices and planning tips in managing cross border employee mobility to improve the bottom line of your business

Programme Outline     

Corporate Tax Implications

Using Tax Treaties to Mitigate or Limit Foreign Tax Exposure

  • What is the risk of being taxed overseas?
  • Introduction to tax treaties
  • Application of the Business Profits Article to mitigate foreign tax exposure
  • Determination of PE in the context of the Business Profits Article
    • What is PE?
    • OECD Model Treaty vs UN Model Treaty
    • Interpreting the “number of days” rule
  • PE issues with the following arrangements/scenarios:
    • Secondment of employees overseas
    • Employees working on short-term and long-term projects overseas
    • Singapore Head Office employees travelling overseas to discharge duties 
    • Singapore company employing foreigners working overseas

 Singapore Corporate Tax Issues

  • Deductibility of expenses relating to employees working overseas
  • Issues relating to recharging of employee costs to overseas entities
  • Withholding tax issues on payments made to overseas manpower suppliers
  • Withholding tax issues relating to certain expenses incurred by employees travelling overseas
  • Withholding tax issues on certain payments made to non-residents with respect to overseas projects/overseas representative office
  • Tax incentives for internationalisation

Individual Tax Implications

Using Tax Treaties to Mitigate or Limit Foreign Tax Exposure

  • Source rules of employee taxation under tax treaties
  • Interpreting the tax treaty provisions relating to employees
  • Understanding the conditions for claiming tax exemption under tax treaties for local employees working overseas

Singapore Individual Tax Issues

  • Taxation of foreign sourced income
  • What is foreign sourced income?
  • Employer’s obligations
  • Special case: Payments to non-resident directors
  • Double taxation and claiming foreign tax credits
    • Treaty relief and unilateral tax relief
    • Conditions for claiming foreign tax credits
    • Determination of residency
    • Documentation requirements

Expert Speaker

Sivakumar Saravan, Senior Partner, Tax and Corporate Advisory, Crowe Horwath Singapore has about 20 years of experience in tax compliance and tax consultancy work for individuals as well as local corporations, multinationals and financial institutions. Siva is a member of Crowe Horwath's International Tax Committee and he has conducted several seminars on international tax to Crowe Horwath tax specialists in the Asia Pacific region as well as to members of the public. He is the author of CCH’s Singapore Withholding Tax And Treaties Online, Crowe Horwath’s Quick Guide to Business Tax in Singapore and Tax Essentials for HR Professionals’.  He is the consultant editor of CCH's Singapore Master Tax Guide manual. Siva is an accredited tax advisor of the Singapore Institute of Accredited Tax Professionals. He is also a member of The Institute of Singapore Chartered Accountants of Singapore and the Singapore Institute of Arbitrators.

Enquiries: 6211 3935; / 6211 3939;  

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