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 Belgium – Kenny Rasquin

The amendment to Belgium’s inbound beneficial tax regime significantly broadens its scope and impact.

The changes intend to strengthen Belgium’s ability to attract and retain highly-qualified international talent, while improving cost efficiency for employers.

Key changes at a glance:

• The tax-free allowance increases to 35%.
• The EUR 90.000 cap is abolished.
• The minimum salary threshold is reduced to €70k.

These adjustments mean that roles previously outside the regime may now qualify, while existing remuneration structures may no longer be optimal under the revised framework.

The amendments apply to remuneration paid or attributed from 1 January 2025.

Once the law is published, the amendments apply to remuneration paid or attributed from 1 January 2025, if a request is filed in time. This creates a time-bound opportunity to reassess and optimise current arrangements.

For employers with inbound executives or specialists who joined in 2025, a retroactive review of eligibility and structuring is required.

Insight contributed by RSM Brazil – Carolina Rotatori

The President of the Republic sanctioned Law No.15,270 (formerly Bill No. 1,087/2025) published in the Federal Official Gazette (Diário Oficial da União - DOU) on 26 November 2025. The new law introduces structural changes to the Brazilian personal income tax (Imposto de Renda da Pessoa Física - IRPF) rules, effective from the 2026 calendar year.

The reform impacts both ends of the income spectrum: it introduces an IRPF exemption for monthly incomes of up to R$5k, benefiting a large proportion of the population, while also creating new and significant taxation mechanisms affecting wealth planning.

Law No. 15,270/2025 establishes a 10% withholding income tax (Imposto de Renda Retido na Fonte - IRRF) on profits or dividends paid, credited, delivered, or remitted, and so ending the exemption that had been in force since 1996.

Furthermore, the law establishes the minimum IRPF (IRPFM) for individuals with total annual income (including dividends and exempt income) exceeding R$6m, starting in 2026.

Profits or dividends paid, credited, delivered, used, or remitted abroad, will be subject to withholding income tax at a rate of 10%), regardless of the amount.

Assessment and action regarding the transition regime are imperative. The law expressly guarantees that profits and dividends calculated until December 31 2025 will remain exempt, even if they are distributed after the law comes into force. To preserve this exemption, it is essential that the company’s distribution resolution be formalised by December 31 2025, with the payment, credit, use, or delivery of these amounts permitted during 2026, 2027 and 2028 calendar years. This measure aims to apply the current exemption rules and mitigate the impact of the new 10% taxation.

Insight contributed by RSM Ireland – Suzanne O'Neill and Caoimhe Neary

Revenue recently published an eBrief on the tax treatment of staff meals which provides clearer guidance in cases where canteen facilities are provided.

From 1 October 2025, where specific conditions are met, staff meals, working lunches and meal vouchers will not be subject to payroll taxes.

Meals provided to all employees on the employer’s premises

A charge to tax will not arise where all the following conditions are met:

• The meals are made available to all staff.
• The meals are consumed on the employer’s premises.

The Revenue guidance no longer requires the meals be provided in a designated staff canteen.

Working lunches for certain employees

A charge to tax will not arise where all the following conditions are met:

• A specific operational requirement exists.
• The meals are consumed on the employer’s premises.
• The total cost per employee doesn’t exceed the subsistence civil service day rate, currently €19.25 per day.

Meal vouchers for employees

From 1 October 2025, the 19c deduction on employer-provided meal vouchers no longer applies. This deduction had previously been allowed when taxing meal vouchers provided to staff.

Insight contributed by RSM Switzerland – Augustin dela Chapelle

The question of how the new high-income contribution (so-called in French ‘CDHR’) raises specific issues for cross-border workers residing in France and employed in Switzerland, particularly when their employment income is taxed in Switzerland.

This situation differs from that of frontier workers covered by the 1983 France–Switzerland tax agreement, which applies in cantons such as Vaud, Basel or Neuchâtel, where salaries are, in principle, taxable in France.

CDHR is an additional contribution levied on taxpayers whose income exceeds certain thresholds. Its calculation is based on the reference tax income (revenu fiscal de référence – RFR), which covers all household income, including income earned abroad, even where that income is already taxed locally.

Method of calculation: key principles

1. Starting point: adjusted reference income

The CDHR is calculated on the basis of all income included in the RFR, including Swiss-source salaries.

Even when a tax credit equal to the foreign tax is granted to prevent double taxation, this income remains part of the RFR used for the CDHR computation.

2. CDHR applicability test

The tax authorities compare the following:

• 20% of the adjusted reference income.
• Minus French tax, recalculated as if the foreign tax credit had been paid in France.

This method prevents the tax credit, granted solely to eliminate double taxation, from artificially reducing French tax to zero in the CDHR calculation.

3. Result

If the difference between these two values is positive, that amount corresponds to the CDHR payable.

Why this approach?

• Foreign income, even when taxed in Switzerland, remains in the RFR used for the CDHR calculation.
• The tax credit, although it neutralises French taxation on those incomes, is still included in the comparison to determine whether additional tax is due.
• In practice, for frontier workers taxed at source in Switzerland, the recalculated French tax is typically sufficient to eliminate any delta, meaning that in most cases no CDHR is owed.

Areas of uncertainty

• The French tax authorities have not issued detailed guidance on this situation involving frontier workers with Swiss-taxed income.
• The official tax simulator does not adequately handle complex cases, such as foreign income, income averaging, or mixed frontier tax situations.
• As a result, certain interpretations remain open, making a case-by-case review necessary.

Summary

• Swiss-source employment income is included in the CDHR calculation base.
• The tax credit corresponding to Swiss-source taxation is taken into account in the adjusted French tax.
• In most cases, frontier workers taxed in Switzerland do not owe CDHR, but a numerical verification remains essential.

Insight contributed by RSM UK – Joanne Webber and Ian Jones

HMRC has updated its guidance on employment-related securities (ERS) reporting. This has clarified the rules for short-term business visitors.

PAYE for short-term business visitors

Short-term business visitors (STBV) are employees of overseas companies who work temporarily in the UK to benefit a UK employer. This normally involves international groups of companies and can have tax implications.

In many cases, the UK employer can apply to be exempt from deducting PAYE from these individuals’ pay (called an Appendix 4). This arrangement can work if:

• The employee is resident in a country with a double taxation agreement (DTA) with the UK and:
  - They spend no more than 183 days in the UK in any 12-month period.
  - Their pay is not ultimately borne by a UK entity.
  - If these conditions aren’t met, PAYE may still be due.

Employers must keep accurate records of the employee’s UK workdays and report these annually to HMRC.

Do the same rules apply to employment-related securities reporting?

Under ERS rules, businesses must submit returns to HMRC by 6 July following the end of the tax year. These returns should report most transactions in shares, options or other forms of security (eg loan notes, carried interest) involving employees and directors. This includes non-executive directors and UK participants of overseas plans.

In July 2025, HMRC announced that individuals included on the STBV report still needed to have details of their ERS reported regardless of there being no UK tax or social security being due. This requirement would significantly increase the compliance costs for employers. HMRC announced a change to this policy in February 2026 stating that individuals on the STBV report would only need to be included on the ERS report if some of their ERS gains were liable to UK tax or social security. This is a substantial reduction in the reporting obligations.

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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