The OECD has launched a public consultation on the tax challenges arising from the increasing global mobility of individuals, including cross-border remote working, short-term assignments, and highly mobile professionals. The consultation seeks stakeholder input on how existing international tax rules apply to mobile individuals and where clarification, coordination, or reform may be needed to ensure tax certainty, fairness, and administrability.
CFE Tax Advisers Europe has published an Opinion Statement in response to the OECD consultation, highlighting practical challenges faced by taxpayers, employers, and advisers, and calling for clearer, more coherent international guidance to address the tax consequences of individual mobility in a post-pandemic environment.
Executive Summary
CFE in its Statement makes the following observations in its input:
- Global mobility of individuals has intensified due to remote working, short-term cross-border stays, and more flexible employment models, placing significant strain on existing tax rules.
- Current international frameworks, including tax treaties and domestic residence rules, often lack clarity when applied to mobile individuals, leading to uncertainty, double taxation risks, and disproportionate compliance burdens.
- Inconsistent interpretation and application of residence, permanent establishment, and employment income rules across jurisdictions create challenges for both taxpayers and tax administrations.
- CFE emphasises the need for clearer OECD guidance on residence determination, days-count tests, remote working arrangements, and employer obligations in cross-border contexts.
- Proportionality and administrability should be central considerations, particularly for short-term mobility and low-risk situations, to avoid excessive reporting and compliance requirements.
- Improved coordination between tax authorities, including enhanced dispute prevention and resolution mechanisms, is essential to ensure tax certainty for mobile individuals and their employers.
CFE Opinion Statement
CFE Tax Advisers Europe submitted this Opinion Statement to the OECD to provide practical insights from European tax advisers who regularly assist individuals and employers navigating cross-border mobility. The consultation reflects the OECD’s recognition that traditional tax concepts, developed in a more static working environment, are increasingly misaligned with modern patterns of work and movement.
The CFE submission highlights that while existing international tax principles remain broadly relevant, their application to globally mobile individuals is often unclear and inconsistent. Issues such as tax residence, source taxation of employment income, social security coordination, and employer compliance obligations can result in overlapping taxing rights, increased administrative complexity, and uncertainty for taxpayers acting in good faith. These challenges are particularly acute for remote workers, short-term assignees, and individuals with multiple work locations.
CFE supports the OECD’s efforts to improve clarity and coherence in this area and calls for pragmatic guidance that reflects real-world mobility patterns. The statement stresses the importance of proportionality, simplification, and legal certainty, especially where mobility is temporary or economically limited. It also underlines the need for effective dispute prevention tools and accessible dispute resolution mechanisms to mitigate double taxation risks and foster taxpayer confidence.
Conclusion
The statement concludes by encouraging the OECD to work closely with jurisdictions and stakeholders to develop clear, consistent, and administrable approaches to taxing globally mobile individuals. CFE stands ready to continue contributing practical expertise to support the development of a fair, modern, and sustainable international tax framework for individual mobility.
We invite you to read the full Opinion Statement for further detail and remain available for any questions you may have.