The OECD is developing proposals on the taxation of globally mobile workers, with more concrete outputs expected by the end of 2026.[cite:483][cite:479] The project reflects the growing pressure that cross-border remote work, hybrid arrangements and short-term international mobility place on rules that were designed for a more traditional model of work.[cite:492][cite:497]
The OECD launched its public consultation on the “Global Mobility of Individuals” project on 26 November 2025, with comments closing on 22 December 2025.[cite:492][cite:483] The consultation was initiated after members of the Inclusive Framework agreed in April 2025 to explore whether existing international tax rules are creating unnecessary friction for modern patterns of cross-border work.[cite:498][cite:492]
For businesses, the concern is not limited to employee taxes. The consultation expressly raised issues around personal tax residence, treaty allocation of taxing rights, payroll and withholding obligations, social security interactions, permanent establishment exposure, corporate residence concerns and transfer pricing consequences arising from mobile employees.[cite:492][cite:496]
What was discussed on 20 January 2026
The OECD held a full-day public consultation meeting in Paris on 20 January 2026 to discuss the issues raised in stakeholder submissions.[cite:479][cite:483] According to the published agenda and stakeholder summaries, the meeting covered economic trends in global mobility, the risks and opportunities created by new ways of working, corporate income tax questions, employment income issues and administrative challenges.[cite:487][cite:497]
A major focus was whether current rules are proportionate for common business scenarios such as short-term business travel, cross-border remote work and hybrid working models.[cite:497][cite:491] Stakeholders also discussed whether globally mobile employees should trigger permanent establishment or profit attribution consequences too easily, particularly where the employee works remotely without a deliberate business presence in the host jurisdiction.[cite:481][cite:490]
Themes emerging from business and advisers
Business groups and professional bodies broadly called for simplification, legal certainty and greater consistency across tax and social security systems.[cite:482][cite:497] Many submissions argued for safe harbours or threshold-based approaches for limited-duration remote work and business travel, clearer guidance on permanent establishment risk, and more practical treatment of residence and employment income allocation questions.[cite:481][cite:484][cite:500]
Another recurring theme was the need to align tax administration with commercial reality. Respondents highlighted that employers can face disproportionate compliance burdens where a small amount of cross-border working creates multiple registrations, filings, withholding obligations or documentation requirements.[cite:482][cite:497]
Practical implications for employers
Even before any OECD recommendation is finalised, the direction of travel is clear: tax authorities and policymakers are trying to update the framework for a workforce that is increasingly mobile, digital and internationally dispersed.[cite:492][cite:497] Groups with cross-border employees should therefore revisit remote-work policies, payroll processes, PE risk assessments and documentation around where key decision-makers and employees are physically performing their roles.[cite:481][cite:496]
For boards, CFOs and legal teams, this is also a governance issue. Mobile senior personnel can create not only payroll and employment tax questions, but also more strategic issues around permanent establishment, transfer pricing and, in some cases, corporate residence narratives.[cite:492][cite:496]