Cross-Border Employment: Aligning Corporate Income Tax, Transfer Pricing and Wage Tax

The authors assess how cross-border employment arrangements require a closer look in the post-BEPS era. As the definitions of “permanent establishment” and “economic employer” have been widened, both transfer pricing and wage tax issues are to be mapped and analysed by corporate, multinational taxpayers. This article discusses a number of issues involved with aligning corporate income tax, transfer pricing and wage tax.