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 Australia – Rick Kimberley

Employers continue to face strong regulatory scrutiny across superannuation, payroll and workplace compliance. In March 2026, attention centred on the progression of Payday Super reforms, increased wage compliance activity and clearer guidance of employer obligations following recent court decisions.

Payday Super preparation remains critical

The Australian Taxation Office (ATO) has released draft guidance to support the implementation of Payday Super from 1 July 2026. This covers law companion rulings on qualifying earnings, contribution timing, Superannuation Guarantee Charge (SGC) calculations and transitional arrangements. Legislative changes affecting onboarding have also passed Parliament. Employers should prioritise system readiness, payroll testing and cash flow planning.

Payroll and wage compliance remains an enforcement priority

Payroll and wage compliance continues to attract strong regulatory focus. Operation Crimson has involved co-ordinated ATO and Fair Work activity targeting wage and superannuation compliance in the hospitality sector. Recent enforcement action highlights the importance of accurate payroll systems, good record keeping and strong governance.

Fringe benefits tax (FBT) and employment tax issues remain in focus

Recent court decisions continue to clarify employer obligations across employment-related taxes. Key developments include guidance on FBT treatment of luxury vehicles, payroll tax applying to subcontracted arrangements and the continued enforcement of director penalty notices. These outcomes show the ATO’s ongoing focus on employment tax compliance.

Insight contributed by RSM Canada – Debra Moses

If your organisation has employees working physically in Canada, even temporarily, you may have Canadian payroll obligations. This applies even if you do not have a legal entity in Canada.

Recent enforcement trends show increased scrutiny on:

• Remote workers relocating to Canada
• Short-term business travellers
• Cross-border US.– Canada employees
• Equity compensation tied to Canadian workdays.

When do Canadian payroll obligations apply?

Payroll requirements are generally triggered when an employee performs services physically in Canada, when compensation relates to Canadian workdays, or when a remote employee moves to Canada without formal reassignment.

Physical presence, rather than corporate registration, is the main trigger.

Required employer withholdings

International employers must typically:

• Withhold federal and provincial income tax
• Deduct Canada Pension Plan (CPP) contributions
• Deduct employment insurance (EI) premiums
• Remit employer portion of CPP and EI
• File annual T4 slips and T4 summary.

Failure to withhold can result in penalties, interest and potential director liability.

Non-resident employer relief

Employers may apply for ‘qualifying non-resident employer’ status if:

• Resident in a treaty country
• Employee is treaty-exempt
• Employee is present less than 90 days in a 12-month period
• Income thresholds or treaty conditions are met.

If approved, income tax withholding may not be required and CPP/EI obligations may still apply unless exempt under a social security agreement.

Relief requires formal Canada Revenue Agency (CRA) approval before reliance.

Key compliance deadlines

International employers may need to:

• Register for a CRA payroll account (RP number)
• Remit payroll deductions monthly or quarterly
• File T4 slips by the end of February
• Maintain Canadian payroll records.

Late remittance can result in penalties up to 20% plus interest.

How we can help

We can help to determine whether your company would qualify for an exemption and if so, to file the necessary applications. We can also assist in the payroll calculations, including whether a shadow or split payroll is required.

Insight contributed by RSM Ireland – Suzanne O'Neill

In an e-brief published by Revenue in May 2024, Revenue offered employers a one-off opportunity to disclose tax where employees that had been incorrectly treated as self-employed individuals and consultants, rather than employees. Where certain conditions where met, preferential tax rates were offered to these employers, with no penalty or interest applied.

This disclosure opportunity allowed employers to correct genuine classification errors for 2024 and 2025 up until the deadline of 30 January 2026.

This action followed the Supreme Court decision in 2023 in the Revenue Commissioners v. Karshan (Midlands) Ltd t/a Domino’s Pizza. After this judgment, Revenue introduced a new five-step framework in May 2024 to help determine if a contractor was an employee or self-employed. This judgement has had wide-reaching implications across all sectors.

What could this mean for your business?

Even though the Kashan Disclosure window has now closed, businesses should continue to review the classification of contractors, using the new five-step framework. Where workers may have been incorrectly treated as self-employed, businesses may face exposure to underpaid PAYE, Universal Social Charge (USC) and Pay Related Social Insurance (PRSI). We recommend that businesses should take appropriate steps to apply the correct tax treatment where the arrangement is now considered to be similar to employment.

Insight contributed by RSM Ireland – Caoimhe Neary

Ireland’s new pension auto enrolment regime, My Future Fund, came into effect from 1 January 2026. It introduces mandatory retirement savings for eligible employees aged 23 to 60 earning more that €20k per year who are not already members of an Irish occupational pension scheme.

From a global mobility perspective, the regime applies only to employees who are within the Irish social security system. Inbound assignees who hold a valid A1 Certificate (or Certificate of Coverage) and remain insured in their home country are generally outside the scope of Irish auto enrolment for the duration of that coverage. This position is typically reflected, consistent with Department of Social Protection guidance. Employers with a mobile workforce in Ireland should therefore ensure that social security positions and payroll classifications are carefully monitored, as changes in A1 status may trigger new auto enrolment obligations in Ireland.

Recent Revenue compliance activity - enhanced reporting requirements (ERR)

Revenue has increased compliance activity in relation to Ireland’s ERR. Level 1 compliance interventions have been issued to employers that failed to file ERR returns or submitted incomplete information.

ERR requires employers to report certain expenses and benefits to Revenue on a real time basis, including non taxable travel and subsistence payments. While Revenue initially adopted a supportive approach following the introduction of ERR on 1 January 2024, this has now moved into formal compliance action. Unresolved issues may escalate to a Level 2 compliance review.

From a global mobility perspective, outbound assignees who remain on Irish payroll but are subject to a PAYE exclusion order are generally outside the scope of ERR. In contrast, inbound assignees operating through an Irish shadow payroll remain within scope. Non taxable travel and subsistence payments processed through payroll should therefore be reported under ERR. Employers with internationally mobile workforces should therefore ensure that ERR reporting is accurate, complete and up to date.

Insight contributed by RSM USA – Audra Marshall

Global instability can necessitate the rapid evacuation of employees from foreign locations. While the immediate focus is on employee safety and security, these crisis-driven relocations trigger significant US tax and mobility consequences for both employers and their employees. Proactive planning can help manage these complex issues.

Foreign earned income exclusion challenges

Many US expatriates rely on the foreign earned income exclusion (FEIE) under Section 911 to mitigate double taxation. To qualify, an individual must meet either the bona fide residence test or the physical presence test, both of which require spending a minimum amount of time in a foreign country.

An employee evacuated before satisfying these time-based requirements may forfeit the ability to claim the FEIE for that year. The tax law provides a waiver for individuals who must leave a country due to ‘war, civil unrest, or similar adverse conditions, this waiver is not automatic. It applies only to specific countries and time periods formally designated by the Internal Revenue Service (IRS), which typically occurs in the year following the event. This creates a period of uncertainty for evacuated employees who have not yet met the minimum time requirements.

Employer-provided disaster relief

Employers often wish to provide financial assistance to employees impacted by an evacuation. Generally, reimbursing an employee's personal expenses results in taxable wages. However, under Internal Revenue Code Section 139, employers can make tax-free ‘qualified disaster relief payments’ to employees.

A ‘qualified disaster’ includes events resulting from terroristic or military action. Payments may reimburse employees for reasonable and necessary personal, family, and living expenses incurred as a result of the disaster. These payments are excludable from the employee's gross income but remain tax-deductible for the employer. To ensure compliance, employers should establish a clear policy for administering these payments, outlining eligibility and the process for employees to attest that their expenses qualify for relief.

Permanent establishment and payroll considerations

Relocating employees to a new country, particularly one where the company is not registered to do business, can inadvertently create a ‘permanent establishment’. This can expose the company to corporate income tax in that jurisdiction. In addition to permanent establishment considerations, employers must research the payroll withholding, reporting and local compliance obligations of any new temporary work location.

What employers should do after an evacuation

While employee safety remains the priority during an evacuation, the global mobility tax implications are significant and complex. The current global landscape underscores the importance for companies to review their emergency policies and ensure that clear communication protocols are in place. Taking these steps can help businesses manage risk, support affected employees and navigate the post-evacuation period effectively.

Insight contributed by RSM UK – Ian Jones

The ongoing conflict in parts of the Middle East is prompting more employees to return to the UK, potentially even for short periods. That can unexpectedly shift individuals back into UK tax residence, bringing worldwide income and capital gains into UK tax. This is particularly relevant for those who left after 5 April 2024 and returned permanently before 6 April 2026. It may also apply to those who ceased UK residence within the last five years, where certain capital gains since departure may become taxable.

UK residence is determined by the Statutory Residence Test and is primarily based on the number of days spent in the UK. Up to 60 days may be ignored for ’exceptional circumstances’. However, this is usually linked to Foreign, Commonwealth and Development Office advice to ‘avoid all travel’. Most recent guidance to ‘avoid all but essential travel’ may not qualify, which creates uncertainty.

Employers may need to restart PAYE and National Insurance deductions and reassess NI positions, including the six-week rule and potential new 52-week periods. There are also risks for UK employers with overseas branches, overseas employers inadvertently creating a UK permanent establishment and Employer of Record arrangements triggering UK payroll liabilities. Temporary workplace relief may be available for some travel and subsistence costs, but only where it is clearly documented that the employee will return overseas within 24 months.

Next steps for employers

Employers need to discuss the situation with affected employees and find out what they want to do in the long term. In periods of uncertainty, it is important for employers to consider the tax and social security implications early to avoid any unintended consequences. Read our full article on UK tax considerations for returning employees.

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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