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Let's Talk About Nomad Employees!

Let's Talk About Nomad Employees!

Over the years, a consensus developed overseas that the U.S. doeEmployees working from overseas is hardly a new phenomenon. However, the COVID-19 pandemic forced employees to work remotely. Indeed, some were forced to work abroad under lockdown or shelter-in-place rules. Not surprisingly, remote working morphed into nomad employees choosing to work from anywhere, any place, in any time zone. The hiring of remote employees brings with it exposure to all sorts of remote taxes for the employer in each place where a remote worker is based. Is there a P.E. for corporate income tax? Is there a fixed base for V.A.T.? Are there income tax withholding obligations for compensation payments? Are there social security obligations? Martin Phelan, a Partner in the Dublin Office of Simmons & Simmons where he is Head of Tax, and Fiachra Ó Raghallaigh, an Associate in the Dublin Office of Simmons & Simmons, provide big picture commentary. Interestingly, the United Nations Tax Committee is examining the policy issues that face nations and employers.

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New Italian Transfer Pricing Regulations Affect Multinational Enterprises

New Italian Transfer Pricing Regulations Affect Multinational Enterprises

Italian transfer pricing documentation rules were introduced in 2010. The system affords taxpayers the possibility of penalty protection for transfer pricing adjustments, provided that qualifying transfer pricing documentation is maintained by the taxpayer. Late in 2020, new regulations were introduced. The new regulations contain several important changes for multinational enterprises based in Italy or having an Italian member. Marco Valdonio, a partner of Maisto e Associati, Milan, and Mirko Severi, an associate of Maisto e Associati, Milan, explain the principal revisions to the Italian rules. They address the changes that broaden the scope of companies required to maintain a master file, reductions in the scope of the exception to annual filing for certain local members of a foreign-based multinational group, and changes to the content of both the master file and the local file.

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