Global mobility update 2026

RSM’s global mobility update provides key mobility and tax developments from across the RSM network. Drawing on insight from specialists across multiple countries, it delivers clear, practical guidance on regulatory and policy changes affecting internationally mobile employees and the businesses that support them.

Our update is designed to help you identify emerging issues and manage cross-border mobility with greater confidence and control.

Key global mobility updates from around the RSM network

Updates from RSM member firms highlighting recent changes across key mobility jurisdictions.

Insight contributed by RSM Canada – Debra Moses

What is Canadian departure tax?

Leaving Canada can trigger an immediate Canadian tax charge, making it important to review assets before departure. Individuals who leave Canada are generally deemed to sell most property at fair market value immediately before departure and reacquire it at the same value afterwards. This is the centre of Canada’s departure tax regime.

The departure-date fair market value matters in two ways:

• First, it determines any gain or loss recognised on departure. If the market value is higher than its adjusted cost base, a capital gain may arise even if nothing has been sold.
• Second, that value becomes the property’s new starting point for tax purposes. If Canada later taxes the property when sold, any gain or loss will be measured from this amount.

Which assets are excluded from Canadian departure tax?

Importantly, departure tax does not apply to every asset. Certain categories of property are excluded from departure tax rules. These include:

• Canadian real estate or immovable property.
• Business property used through a permanent establishment in Canada.
• Specific excluded rights or interests.
• Some short-term resident property.
• Property covered by a later returning-resident election.

The definition of ‘excluded rights or interests’ is broad and includes:

• Registered plans
• Pension rights
• Employee benefit interests
• Trust interests
• Life insurance interests.

Can departure tax be deferred?

It is also important to consider whether security should be provided to defer payment of the departure tax. Individuals may be able to elect to defer payment, provided the election is made by the filing deadline for the year of emigration.

Where a valid election is made, the Minister must accept adequate security for the amount deferred. Interest and penalty consequences are also modified while the security remains in place. The Minister may extend the deadline for making the election or providing security where it is just and equitable to do so.

The Canada Revenue Agency (CRA) guidance confirms that the election defers payment of the tax, not the deemed disposition itself. Arrangements for any required security should therefore be made by the filing deadline for the year of emigration.

Canadian departure tax reporting requirements

There are also compliance obligations. Individuals who leave Canada and hold reportable property above a fair market value of $25k, may be required to file the prescribed property list by the filing-deadline.

CRA guidance identifies Form T1243 for reporting deemed dispositions, Form T1161 for the property list and Form T1244 for the security election.

What should individuals do before leaving Canada?

Leaving Canada can have tax consequences that are not always expected. Under the departure tax regime, a tax charge can arise simply because an individual ceases to be a Canadian tax resident, even where no assets have been sold. In addition, reporting obligations may continue after departure and decisions may need to be made around available elections and payment deferrals.

To help manage these obligations and avoid unexpected tax costs, individuals should:

• Confirm that Canadian residence has ended.
• Identify which assets are subject to the deemed disposition rules.
• Determine whether exclusions or elections apply.
• Establish reasonable market values.
• Assess whether posting security is appropriate for any resulting departure tax.

Reviewing these issues before departure can help individuals understand their exposure, meet their compliance obligations and leave Canada with greater certainty and fewer surprises.

Insight provided by RSM Ireland - Caoimhe Neary and Micah Yuson

Auto-enrolment pension scheme: what inbound assignees need to know

Ireland’s new auto-enrolment pension scheme, also known as My Future Fund, came into effect on 1 January 2026. It automatically enrolled eligible employees aged 23–60 earning more than €20k per year who are not already contributing to a workplace pension through payroll.

With the first opt-out window having opened on 1 July 2026, a milestone has now been reached. Employees who have been enrolled for six months can opt out during this two-month window and receive a refund of their own contributions during this time. However, they will miss out on employer and state contributions. If they are still eligible, they will be automatically re-enrolled after two years.

From a global mobility perspective, employers should continue to monitor the position of inbound assignees and other internationally mobile employees. Auto-enrolment only applies to employees who are subject to Irish social security. Individuals who remain covered by a foreign social security system under a valid A1 Certificate or Certificate of Coverage, will generally remain outside the scope of the regime.

For mobile employees who have been automatically enrolled because of becoming subject to Irish social security, the opt-out window provides an opportunity to review their pension arrangements and decide whether remaining in the scheme is appropriate.

2025 payroll self-corrections: key deadline approaching

Employers who identify an incorrect or incomplete payroll submission for the 2025 tax year may still have an opportunity to regularise the position after year-end without penalty, by way of Self Correction. Under Revenue’s Code of Practice for Compliance Interventions, self-correction without penalty requires:

• Advance written notification to Revenue within the applicable time limit (eg before the corporation tax deadline for the payroll period).
• A supporting calculation outlining the correct tax and interest due.
• Payment of any additional tax, Universal Social Charge (USC), Pay Related Social Insurance (PRSI) and applicable interest with the correction.

For employers with a 31 December 2025 financial year-end who pay and file through Revenue Online Service (ROS), the deadline to make a self-correction is 23 September 2026. This reflects the rule that self-correction must be made within nine months of the end of the accounting period in which the payroll period falls.

For international businesses and globally mobile workforces, this is a timely reminder to review prior-year payroll reporting and identify any Irish PAYE, USC or PRSI adjustments before the self-correction window closes. Where errors or omissions are identified early, the self-correction process can provide a practical route to regularising the position while mitigating potential penalty exposure.

SARP filing season: practical challenges and lessons for employers

Employers recently completed their annual SARP compliance obligations ahead of the 30 June 2026 filing deadline, which was extended from the previous 23 February deadline.

Despite the additional time available, there are many practical challenges when preparing SARP filings. One of the most common issues is gathering accurate remuneration data, particularly where employees receive equity compensation, bonuses, allowances, tax equalisation benefits or pension contributions that are administered across multiple jurisdictions or payroll providers.

The amount to be reported on the return is the gross income from the employment before the deduction of SARP relief, less amounts contributed to pension and amounts not subject to Irish tax. Revenue guidance also contains specific provisions for tax equalisation arrangements and the calculation of qualifying income, meaning that detailed analysis is often needed before the final SARP position can be determined.

Employers also regularly encounter difficulties ensuring that all qualifying conditions have been met. This can include verifying overseas employment history, tracking Irish work commencement dates, obtaining PPS numbers and ensuring the relevant certification requirements have been met within the prescribed deadlines.

In practice, these administrative requirements can be particularly challenging where responsibility for assignee data is spread across multiple teams and jurisdictions.

From a global mobility perspective, this year's filing season reinforced the importance of maintaining accurate records throughout the year, rather than leaving information gathering until shortly before the reporting deadline. Close coordination between payroll, HR, global mobility and tax teams can significantly reduce the risk of omissions, particularly where assignees receive complex remuneration packages or benefits that are not fully captured through Irish payroll.

Insight contributed by RSM Netherlands – Brian James

Fossil-fuel car levy from 2027: key developments for employers

As of 1 January 2027, the ‘pseudo-final levy’ on fossil-fuel passenger cars will come into effect. In principle, employers will be liable for a 12% levy on a vehicle’s list price where a fossil-fuel passenger car is made available to an employee and can be used privately. For these purposes, commuting between home and work is also treated as private use.

Following consultation with the sector, the government has proposed several practical adjustments. For example, a fossil-fuel replacement car provided while a vehicle is undergoing repairs, maintenance or a tyre change would remain outside the scope of the levy for up to 14 consecutive days.

In addition, it is proposed to extend the transitional rules from 17 September 2030 to 1 January 2031. Until that date, an exemption for one period of up to seven consecutive days per calendar year would also apply. A specific exemption for driving school cars is also expected.

It has also been clarified that, for internationally mobile employees, a treaty-based allocation of taxing rights may also have an impact on the pseudo-final levy.

Incidental taxi use does not trigger the pseudo-final levy, as no car is made available to the employee for the purposes of this measure.

The transitional rules are, in principle, linked to the employer and the vehicle. If there is a transfer to another employer with a different wage tax number, the transitional rules will cease to apply, even where the employers are part of the same group. An exception may apply in certain mergers and acquisitions scenarios.

Practical point

With less than six months until the levy takes effect, employers should use 2026 to assess the potential financial and administrative impact on their organisation and identify any gaps in their current processes. In particular, employers should establish which fossil-fuel cars fall within the transitional rules and ensure that temporary replacement cars, internationally mobile employees and changes of withholding agent are properly tracked and recorded. Early preparation can help avoid unexpected costs and reduce administrative burdens once the new rules take effect.

Work-related costs scheme reforms: implications for staff discounts and employee benefits

Following the evaluation of the Dutch work-related costs scheme, the government has announced several measures aimed at simplifying the scheme. While some of the proposals form part of the decision-making process in August 2026, and are therefore not final, employers may wish to begin considering how the changes could affect employee benefits and reimbursements arrangements from 2027.

One of the most significant proposals is the abolition of the separate exemption for discounts on products and services from the employer’s own business as of 2027. As a result, such staff discounts may then have to be designated as final levy wage and charged to the ‘discretionary scope’.

In addition, the government intends to formalise the so-called efficiency threshold for all reimbursements, provisions and benefits made available that are charged to the discretionary scope. Annual indexation of this threshold is also proposed.

Other possible changes include:

• The abolition of the first bracket of the discretionary scope.
• The abolition of the long-service exemption for anniversary payments after 25 and 40 years of service.
• Allowing the targeted exemptions for working-from-home expenses and travel expenses to apply concurrently.
• Further substantiation and possible adjustment of the final levy rate.

The government is also exploring whether employers can support employees in repaying their student debt more quickly through the work-related costs scheme. The targeted exemption for education and study will remain in place and will be brought more actively to employers’ attention.

Practical point

Although the proposals are not yet final, employers may wish to review how the potential changes affect their current work-related costs policy and employee benefit arrangements. Particular attention should be paid to staff discounts, anniversary payments, working-from-home and travel allowances, student debt arrangements and benefits such as company fitness schemes. Once the proposals have been finalised and any legislative changes confirmed employers can assess what changes, if any, will be required from 2027.

New Dutch labour supply rules: why employers should review their hiring chain now

The Dutch Act on the Admission of Labour Supply Agencies (Wtta) is expected to enter into force on 1 January 2027. Under the new rules, temporary employment agencies and other businesses that supply workers will only be allowed to do so if they have been admitted to the Dutch Labour Supply Market Authority.

The scope of the act is broader than the traditional temporary employment sector. Other forms of labour supply and secondment may also fall within the admission system. As of 1 January 2028, the Dutch Labour Inspectorate will start enforcement. Fines may be imposed not only unapproved labour suppliers, but also hirers that work with a non-approved party.

Practical point

Given the broad scope of the proposed rules, employers should use 2026 to map their full labour supply and hiring chain in 2026. This may include:

• Temporary employment and secondment agencies.
• Subcontractors.
• Intra-group lending of staff.
• Collegial lending of staff.
• Other structures in which employees work under the direction and supervision of another company.

Contract management, supplier due diligence and robust administrative record-keeping are likely to become just as important as payroll compliance.

Pay transparency: why employers should review remuneration data now

On 21 May 2026, the legislative proposal implementing the European Pay Transparency Directive was submitted to the Dutch House of Representatives. The proposed effective date is 1 January 2027. However, the bill must still be approved by both the House of Representatives and the Senate before it becomes law. As a result, both the final provisions and implementation date may still change.

The proposal includes:

• Greater transparency on salary and salary ranges during the recruitment process.
• Objective and gender-neutral criteria for remuneration and job classification.
• Expanded information rights for employees.
• Reporting obligations for certain employers.

For employers with at least 150 employees, the first report under the current legislative proposal is due by 7 June 2028. This report relates to the calendar year 2027. While the Dutch implementing legislation is not yet final, the European directive does require the Netherlands to transpose the rules into national law in a timely manner. The specific obligations for employers, enforcement and sanctions will ultimately depend on the final Dutch legislation.

In particular, employers should assess whether their employee pay policies can be objectively substantiated and whether the available HR and payroll data are sufficiently reliable and consistent. Job information, salary components, working hours and employee characteristics will need to be combined consistently from various systems. This may require considerable preparation, particularly where job classification and remuneration policies are currently recorded in a fragmented manner.

For employers with internationally mobile employees, the impact of the directive remains unclear at this stage. Employees on an international assignment may become entitled to request insight into pay grades for comparable roles in the host country. This could, in turn, influence cross-border agent attraction and retention strategies, as well as wider remuneration and mobility policies.

Insight contributed by RSM Switzerland – Eva de Potter and Augustin de la Chapelle

Major changes are on the horizon for businesses managing cross-border and internationally mobile employees across Europe. Following a landmark Court of Justice of the European Union (CJEU) ruling and a broader reform of EU social security coordination rules, employers may soon need to revisit how they determine social security coverage for employees working in multiple countries, particularly in an era of hybrid working, remote work and increasing international mobility. New guidance is expected to bring greater certainty, but also additional compliance obligations.

The reforms introduce enhanced protections for mobile workers, including changes to unemployment benefits, the formal inclusion of long-term care benefits and new posting notification requirements. While intended to improve consistency and reduce disputes between countries, the changes could have significant implications for social security contributions, benefit entitlement and employer compliance processes. Organisations with employees working across borders, including those with Swiss connections, should pay close attention to these developments and consider whether existing arrangements remain fit for purpose.

For a detailed breakdown, read RSM Switzerland's full update on changes to European social security coordination.

Insight contributed by RSM UK – Ian Jones

Where do cross-border workers pay social security after Brexit?

Brexit has fundamentally reshaped the social security landscape for employees working across UK and EU borders, creating new compliance challenges for internationally mobile workforces. While many of the familiar principles remain in place, employers must now navigate the UK–EU Trade and Cooperation Agreement, determine where contributions are due based on working location and carefully consider the impact of temporary assignments, hybrid working arrangements, and employees who regularly work in multiple countries. Understanding these rules is critical to avoiding unexpected costs, payroll obligations and potential double contributions.

The position continues to evolve as remote and flexible working become more common.

Differences are beginning to emerge between the UK-EU framework and developments within the EU itself, particularly in relation to cross-border homeworking and proposed reforms to social security coordination rules. For organisations with employees moving between jurisdictions, effective tracking of working patterns, robust processes and proactive planning are becoming increasingly important to manage risk and maintain compliance.

For a closer look at the issues, read our full article on social security for cross-border workers after Brexit.

OECD employment tax trends: implications for employers and mobile workforces

The latest OECD data reveals how much of an employee’s total employment cost is absorbed by income tax and social security across 38 member countries, highlighting significant differences between jurisdictions. While the average tax wedge for a single worker rose to 35.1% in 2025, the position varies dramatically, with some countries imposing substantially higher employment tax burdens than others. The findings also show how fiscal drag, increases in social security contributions and changes to tax policy are reshaping employment costs for both employers and employees.

The analysis is particularly relevant for organisations managing international assignments, remote working arrangements and globally mobile workforces. It explores how the balance between income tax and social security differs across countries, the impact of family-related tax reliefs and the longer-term trends emerging since the pandemic. For employers considering cross-border working arrangements, the insights provide a useful reminder that understanding local employment tax costs remains essential for effective workforce planning and avoiding unexpected liabilities.

For additional insight, read our analysis of employment taxation across OECD countries.

UK National Insurance for globally mobile employees: NIC settlements explained

Managing National Insurance for internationally mobile employees can be far more complex than simply running a UK payroll. Different social security agreements, split payroll arrangements, overseas-paid bonuses and benefits and varying assignment lengths can all affect when UK NIC applies and who ultimately bears the cost. Understanding these rules is essential for employers seeking to remain compliant while minimising administrative challenges that often arise when remuneration is paid across multiple jurisdictions.

Where employees are subject to UK NIC but receive remuneration from multiple jurisdictions, modified payroll arrangements can offer a practical solution. By allowing NIC to be calculated on estimated earnings during the year and reconciled through an annual settlement, employers can significantly reduce the challenges of obtaining overseas payroll information in real time. For organisations managing inbound or outbound assignees, these arrangements can streamline compliance while maintaining accurate NIC reporting.

To understand what this means in practice, read our full article on NIC settlements for globally mobile employees.

In case you missed it: is cross-border remote working exposing your business to tax risks?

Cross-border remote working is becoming a key feature of modern employment, but it can create unexpected tax exposures for businesses operating internationally. Recent developments provide greater clarity on when an employee working from home overseas is likely to create a taxable presence for their employer, offering welcome reassurance for organisations that support flexible working arrangements. However, the position is far from straightforward and businesses still need to understand the factors that can trigger tax obligations in different jurisdictions.

While the latest guidance may reduce some of the uncertainty around international home working, it does not remove the wider payroll, employment tax and social security risks that can arise when employees work across-borders. Businesses considering more flexible international working policies should ensure they understand the potential implications, as well as the opportunities, before making changes. With talent attraction and retention increasingly linked to workplace flexibility, getting the balance right has never been more important.

To explore the wider implications, read our article on the tax risks of cross-border remote working.

Insight provided by RSM US- Audra Marshall and Dorothy Celeste

The 2026 World Cup’s next challenge: taxes

The 2026 FIFA World Cup created unforgettable moments, exciting matches and worldwide attention. As the largest World Cup ever staged, it brought together players, coaches, broadcasters, sponsors, officials and support personnel from around the world across host venues in the United States, Canada, and Mexico.

While the tournament is now over and participants are returning home, many still have one important responsibility ahead of them: understanding the tax implications of taking part in the 2026 FIFA World Cup. With matches and related activities taking place across three countries, individuals and organisations may face tax filing and reporting obligations in multiple jurisdictions.

As most World Cup matches were played in the United States, understanding US tax requirements is especially important for many foreign participants.

Understanding US tax exposure

Many international participants earned income while performing services during the World Cup. Depending on their role, this could include:

• Match participation fees
• Appearance fees
• Prize-related compensation
• Sponsorship and endorsement income connected to US activities
• Promotional events
• Media appearances
• Coaching or consulting services.

Income earned from services performed in the United States is generally considered US source income, meaning it may be subject to US federal tax.

The tax treatment often depends on whether the individual is classified as an employee or an independent contractor.

Where an individual is an employee, the payer usually withholds tax from wages under payroll withholding rules. However, independent contractors are often subject to 30% withholding on their gross compensation unless a tax treaty or another exception applied.

As a result, two individuals earning similar amounts could have experienced very different withholding outcomes depending on how their activities were classified.

US withholding and reporting requirements

The person or organisation making the payment is often responsible for withholding US tax and reporting those payments to the Internal Revenue Service (IRS).

Payments to foreign independent contractors are generally reported on Forms 1042 and 1042-S. Employee wages are typically reported through normal payroll reporting, such as Form W-2.

Failure to apply the correct withholding and reporting rules can create compliance risks for both the payer and the recipient, making it important to establish the appropriate treatment before payments are made.

US tax treaty benefits

Many countries have income tax treaties with the United States that can reduce or eliminate US tax on certain types of income. However, treaty relief is not automatic. To claim an exemption from US tax withholding or benefit from a reduced withholding rate, participants generally need to provide the appropriate IRS documentation before payments are made, such as Form 8233 or Form W-8BEN.

Players from countries without an income tax treaty with the United States generally have fewer opportunities to reduce withholding under treaty provisions. As a result, understanding treaty eligibility and ensuring the correct documentation is in place can play an important role in managing tax obligations and avoiding excessive withholding.

Central withholding agreements (CWAs)

Athletes may be subject to special withholding rules. Where a foreign athlete is paid as an independent contractor, the default rule is usually 30% withholding on the gross payment. In some cases, athletes may request a CWA.

A CWA allows withholding to be calculated on estimated net income rather than gross compensation, helping to reduce excessive withholding during the event. Although a CWA can improve cashflow and reduce excessive withholding, it is not a tax exemption. Participants who used a CWA generally will still be required to file the appropriate US tax returns after the tournament.

US tax returns filing obligations

Many World Cup participants may still be required to file US tax returns even if taxes were withheld during the tournament.

Common filing requirements include:

• Form 1040-NR for non-resident individuals
• Form 1120-F for foreign corporations.

Filing a return may be necessary to:

• Report income correctly
• Calculate the actual tax due
• Claim tax treaty benefits
• Request a refund if too much tax was withheld.

Failing to file required returns can result in penalties and may make it difficult to recover over-withheld taxes.

State tax issues

Federal taxes are only part of the compliance picture.

As World Cup matches were played across multiple US states, participants may also have state income tax filing obligations depending on where services were performed.

Each state has its own tax rules, filing thresholds and withholding requirements. As a result, state tax compliance should be considered separately from federal taxation.

For participants involved in activities across multiple locations, understanding where services were performed and whether state-level obligations arise will be an important part of meeting overall tax compliance requirements.

Tax responsibilities beyond the US

The World Cup's three-country format means that many participants may have tax obligations in several jurisdictions, including:

• Their home country
• The United States (federal and possibly state)
• Canada and Mexico.

Although tax treaties and foreign tax credits often help reduce the risk of double taxation, coordinating tax reporting and compliance across several countries can be complex.

Practical considerations for World Cup participants

The excitement of the 2026 FIFA World Cup may be over, but the associated tax obligations may only just be beginning.

Foreign players, coaches, officials, broadcasters and other personnel should review whether they have any outstanding filing or reporting requirements, including the need to file tax returns, claim treaty benefits, or recover excess withholding.

Participants should also consider whether state tax filing obligations arise in addition to federal requirements, particularly where activities took place in multiple locations during the tournament.

Missing filing deadlines or overlooking state tax obligations could lead to unnecessary penalties or missed refund opportunities.

For more information on how these global mobility and tax developments could impact your organisation, speak to Joanne Webber for tailored advice across your international workforce.

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