Exploring special tax regimes for expats in Europe

In this article, we present an overview of the key features of special tax regimes in eight prominent countries: France, Belgium, the Netherlands, Italy, Portugal, the United Kingdom, Spain, and Switzerland.

Explore Employment Tax Year End Overview from FTI Consulting, which summarizes key deadlines and changes for employers in the new tax year 2025/26.

Workation is no longer a foreign word. Workation has established itself in our linguistic usage and it is simply impossible to imagine the modern working world without it.

Obtaining a Work Permit in Vietnam has become more difficult and time-consuming. Get an overview of all issues related to obtaining a work permit, visa, and temporary resident card.

Telework and hybrid work are present as never before. In the case of multi-state workers, this can unfortu­nately bring about a mandatory social insurance in the other country.

The status of remote work in the Labour Code has been changed to a permanent option, rather than one applicable just in relation to the COVID-19 pandemic.

Ensuring greater social justice in the distribution of the tax burden" is one of the objectives pursued by the Amending Finance Law (LFR) for the year 2022.

The concern that the expatriates’ IIT burden might surge after 2023 may revive again.

To increase the efficiency of the organisation’s workforce, many companies have started to implement their global mobility strategies to empower flexibility and to adapt to hybrid and remote working methods.

The Portuguese Law No. 18/2022 approved on 25 August had relevant changes to Law No. 23/2007, also known as “the Foreigner’s Law”, introducing a new Portuguese visa type called the “Digital Nomad visa”.

August 2022 saw the Nigerian Ministry of the Interior release a circular informing the public of a revised Handbook on Expatriate Quota Administration.

As of 1 January 2022, companies that qualify as a withholding agent for Dutch wage tax and so-called collective administering organisations are obliged to notify the Dutch tax authorities of payments made to per­sons who are not on the payroll

With a series of recently published rulings, the Italian Tax Authorities have provided some helpful interpretations of recurring cross-border tax issues.

2023 is starting with significant changes for employees and employers in Hungary: the introduction of new tax allowances, a new type of leave and the minimum wage increasing.

On 22 December 2022, France and Switzerland reached an agreement on the taxation of home office income.

The 1 January 2022 a new expat tax regime introduced in Belgium that provides for a favourable income tax (and social security) treatment for employees, directors and researchers recruited abroad or seconded to Belgium.

The Administrative Court recently decided that an exemption with progression is to be applied to persons with unlimited tax liability in Austria even if they are resident abroad.

The Australian government has committed to expand the Pacific Australia Labour Mobility (PALM) scheme as follows

We are pleased to present the 1st edition of our WTS Global Mobility Newsletter for 2023.

In this edition our member firm WTS Klient summarises important changes affecting multiple areas, from labour law to transfer pricing.

When and where are we taxed on income from employer securities in Hungary?

In the latest WTS CEE article, the most important changes affecting income tax are summarised.

Due to the COVID-19 pandemic, a lot of employees who used to work abroad have been forced to work from home. In order to mitigate the impact, Luxembourg concluded so-called ‘COVID agreements’ with its neighbouring countries in 2020.

The Australian Government consolidated the Seasonal Worker Programme (SWP) and Pacific Labour Scheme (PLS) and operated under the PALM scheme with one visa stream and improvements to cut red tape and improve worker welfare.

Taiwan's Central Epidemic Command Center has announced that effective September 29 citizens of all countries enjoying visa-free treatment may enter Taiwan for business or tourism purposes visa-free, without the special entry permit.

Today, Thailand is already home to multinational corporations from all over the world and one of the most important tourist destinations in Asia.

In principle, every employee recruited from abroad to take up a position in France is affiliat­ed to the compulsory French social security schemes for basic and supplementary retirement pension insurance.

During the year a Ukrainian resident employed by a representative office of a German company in Ukraine has come to Germany and is working remotely for the Ukrainian office.

Decree No. 152/2020/ND-CP (“Decree 152”) came into effect on 15 February 2021 and made the conditions for obtaining a work permit (“WP”) stricter.

According to the UN, more than 6.5 million Ukrainians became refugees and temporarily left Ukraine.

On 1 January 2021, the revised law on the Swiss source tax came into force.

The 30% ruling is a specific tax regime for foreign employees who meet certain criteria and who are temporarily assigned to, or hired from abroad by an employer in the Netherlands.

In a recent case, Italian Tax Authorities have returned to the debated theme of taxation of Italian source pensions paid to non-resident individuals.

Changes are expected in social contribution tax regarding the determination of the taxable portion of income and the concept of the base salary in Hungary.

From 2021, self-employed persons with incomes up to CZK 1,000,000 might pay a flat tax of CZK 5,469 in the Czech Republic, which includes income tax, social security and health insurance.

For more than a decade, Chile has constantly received foreign executives. This is directly related with the high salaries of Chile, among the highest in Latin America, and therefore it is convenient for international executives.

In a legal opinion, the “BMF” has explained under which circumstances a permanent establishment is triggered by home office activities.

An overview of recent or expected changes in the area of Global Mobility in different countries is now available.

Clarifications have recently been provided, through decrees and an order, on the conditions for accessing and consulting data contained in the registers of trusts and “fiducies” (French-style trusts) kept by the French General Directorate of Public Finances (Direction Générale des Finances Publiques, DGFiP).

In three decisions dated 13 July 2021 (nos. 428 506, 435452 and 437 498) and a ruling of 17 November 2021 (no. 439 609), the Conseil d’Etat (French Supreme Administrative Court) has clarified the tax treatment of gains from incentive plans that offer managers an equity interest in the companies they work for  (“management packages”).

Clarifications have recently been provided, through decrees and an order, on the conditions for accessing and consulting data contained in the registers of trusts and “fiducies” (French-style trusts) kept by the French General Directorate of Public Finances (Direction Générale des Finances Publiques, DGFiP).

Clarifications have recently been provided, through decrees and an order, on the conditions for accessing and consulting data contained in the registers of trusts and “fiducies” (French-style trusts) kept by the French General Directorate of Public Finances (Direction Générale des Finances Publiques, DGFiP).

France has an attractive regime to incentivize foreign talents to take up residence in France: the impatriate regime.

The Belgian government agreed in the recent budgetary agreement on important changes for foreign executives falling under the special taxation regime.

The salary of a Belgian tax resident relating to days performed in Luxembourg is generally taxable in Luxembourg according to the Belgium-Luxembourg double tax treaty. The days worked outside of Luxembourg are then taxable in Belgium (state of residence).

#workfromanywhere – Time to balance the benefits and risks

Information about the amendments of the Italian tax regime for “impatriates”.

As a result of measures taken due to the COVID-19 pandemic, numerous questions have risen regarding the social security liability and personal income tax liability of expats.

Udate about the new flat tax in the Czech Republic.

Sweden introduced the economic employer concept as of January 2021.

In Germany, a new fact has been introduced that has led to an obligation for non-residents to file a German income tax return. In the majority of cases, this will cause a considerable additional tax burden in addition to the additional effort of submitting the declaration. It applies as of the 2020 German tax return filing season which should start in 2021.

There is a consultation agreement between France and Germany which should mitigate the tax consequences of home-working days caused by the pandemic.

The extraordinary circumstances that the world faced in 2020 have led to numerous changes in labour legislation worldwide, including in Bulgaria. March 2020 saw Bulgaria declare a state of emergency and adopt an Act on the Measures and Actions during the State of Emergency.

China will see major changes take effect in 2022 regarding the tax honeymoon for expatriates - and this is definitely worth thinking about already now.

Austria made a U-turn and abolished the wage withholding tax for foreign employers just introduced at the start of last year.

An overview of recent or expected changes in the area of Global Mobility in selected EU and third countries is now available.

Article 52 of the Ukraine Law “On International Private Law” specifies that employment relations are governed by the law of the country where the employment is actually exercised, unless otherwise set out by the law or respective international treaty.

With a particular focus on the COVID-19 crisis, our Swedish colleague explains under which circumstances individuals  become liable for tax.

The case: German company A employs person B with residence in Vietnam for working on projects of A in Germany and other countries. A is not registered in Vietnam. A and B intended that B will be working for A in Germany, but this plan cannot be implemented due to COVID-19 restrictions. After these restrictions are lifted, B remains in Vietnam. B does not have an independent business in Vietnam, he is employee.

An overview on legal implications for remote work in Turkey.

The shift to remote working entails several complex issues, as the Portuguese law and authorities may not accompany the pace of change of business and technology.

Dutch authorities concluded an agreement with the Belgian and German authorities to mitigate the tax and social security
impact from working from home.

On 3 April 2020, the OECD issued the “Secretariat Analysis of Tax Treaties and the Impact of the COVID-19 Crisis”, which addresses several tax concerns.

The remote working of employees has raised concerns regarding the creation of PE risks for their foreign employers in Kenya. 

An overview of work-from-home tax regulations in Germany during and after the COVID-19 pandemic.

During the last six months, national governments have applied various measures restricting the movement of people. These measures not only affect the private lives of individuals, but also limit or change the conditions under which said individuals can carry out their work.

Fidal’s International Mobility experts give advise on the major challenges businesses are facing in the context of the current crisis.

The COVID-19 health crisis has led to an exponential spread of the recourse to the remote-working mode, given that the health and safety policies adopted by employers define remote work as a key prevention measure.

Employees working in a different country to that where the registered office of their employer is located raises several taxation issues.

A scenario regarding remote work in Costa Rica during Covid-19 and afterwards.

One question may arise due to the coronavirus: does the coronavirus cause any impact on the IIT of individuals stranded in China?

An analysis of double taxation due to COVID-19 for individuals working abroad

The Austrian tax administration takes a “facts and circumstances-approach” to assess whether home office work creates a permanent establishment (PE) for the foreign employer.

An overview of recent or expected changes in the area of Global Mobility in different countries is now available.

In Germany, employees of a foreign permanent establishment (PE) of a Germany-based company are taxable in Germany from day 1.

Article 13 of the French finance bill for 2020 introduced a new tax domiciliation criterion for executives of large French companies

Costa Rica had important tax amendments relating to different taxes.

Announcements concerning 2019 annual IIT filing and the COVID-19 epidemic.

The Belgium-Luxembourg double tax treaty’s main rule is that if the employment is carried out in Luxembourg, then the salary relating to the days performed in Luxembourg is taxable in Luxembourg and exempted from tax in Belgium.

However, obtaining the exemption for this income in Belgium is not always straightforward.

As per 01/01/2020, the monthly wage withholding tax obligation is extended.

An overview of recent or expected changes in the area of Global Mobility in different countries is now available.