Remote Work

Global | OECD public consultation covering global mobility of individuals

Summary

The OECD held a public consultation meeting covering the global mobility of individuals on 20 January 2026 in Paris, France. There was widespread acknowledgement that new ways of global working were here to stay. However, it was recognised that the international tax framework governing cross-border work has not kept pace and remains disproportionately complex and administratively burdensome.

The key themes of the OECD meeting were aimed at working towards simplicity, clarity and certainty. As ever, the detail of what was discussed is key.

The detail

Why is a review of global mobility important now?

In Vialto’s Mobility Agility report, we explored how world events, technological advancements, shifting employee expectations and evolving business strategies have forged a path for non-traditional forms of mobility such as international remote working, hybrid work models, cross-border commuting and international virtual working arrangements.

In our Mobility Agility survey, we asked participants what changes to current legislation and authority approach would most significantly reduce the challenges associated with operating international remote work programmes. The responses were telling:

• 69% cited the introduction of a universal de minimis threshold for tax compliance actions
• 54% identified social security simplification
• 48% highlighted a relaxation of permanent establishment (PE) thresholds

Representations in the OECD consultation reinforced that international working was widespread, but that existing frameworks, legislation and international guidance were no longer fit for purpose.  The OECD’s guidance on permanent establishment (“PE”) risk for remote workers released in November 2025, was welcomed, but there was a clear consensus that further work is needed. Current compliance requirements often act as barriers to flexible and agile cross-border working, holding back economic growth and limiting employee choice.

What were the key challenges reviewed in the OECD consultation?

The scope of the consultation included wide ranging examples of individuals working internationally—both where employees physically travel but also where an individual works in one country on behalf of an employer located in a different country.

The discussion focused primarily on:

• Short-term international remote workers
• Long-term remote workers or “international hires”
• Cross-border commuters
• Global nomads

Harmonisation with the treatment of business travellers was also considered.

The consultation meeting primarily focused on trends in global work patterns, understanding the business and economic requirements for these arrangements, identifying areas of complexity, uncertainty and additional costs and exploring possible solutions to these challenges.  It particularly focused on issues relating to PE and individual income tax.

What suggestions were explored?

While no commitments were made towards what changes (if any) the OECD would recommend, suggestions explored during the consultation included:

• Globally consistent “safe harbour” or “de minimis” thresholds below which compliance actions were not triggered, aligned across corporate and individual income taxes. Thresholds mooted included the number of days and/or types of work activities performed.  The aim being to remove administration and costs for shorter term arrangements or where lower amounts of tax were at stake.
• Additional guidance on dependent agent activities (to supplement the OECD guidance from November 2025), particularly to avoid the creation of “micro-PEs”.
• Optionality to obtain an upfront ruling on the tax treatment in order to give certainty from the outset.
• Wider adoption of existing specific border rules e.g. the Germany/Austria approach or the France/Switzerland approach.
• Review of branch structure implications on Article 15 application, whereby under existing double tax treaties, individuals employed by a branch who travel to the parent company location are not protected from Day 1 taxation.
• Review of the economic employer concept.

What does it mean for mobility teams and those managing cross-border employees?

Businesses with any kind of global footprint will be affected by any future recommendations from the OECD.  In order to start planning ahead, teams should consider the following:

1. Align to business requirements: With possible simplified employer compliance requirements, international working arrangements that were historically cost-prohibitive or too complex to manage may become more attractive and businesses have an opportunity to utilize alternative work models to achieve their strategic goals.  Examples might include accessing new talent pools by exploring international remote hires or enhancing the employee value proposition by enabling remote work for personal reasons.
2. Tracking of travel: Any relaxations to requirements are likely to have criteria around the number of days or type of work performed.  It will be more critical than ever for employers to have accurate and consistent reporting and tracking telling them who is working, where and when across the different cross border move types (remote work, business travel, longer term or permanent moves).
3. Revisit policies: Future updates from the OECD will hopefully simplify but certainly change the assessment of compliance requirements for international working arrangements.  Be prepared to revisit existing management frameworks to reflect new guidance. As ever, there will be no guarantee that all countries will adopt any recommendations, so governance processes will need to be updated to reflect country-specific approaches.
4. Assess broader risks: Tax is just one of the potential considerations for international work.  Continue to assess and track other risks including right to work (immigration), insurance, Posted Worker Directive and employment law, regulatory considerations, cyber security and personal safety.  Technology solutions can automate risk assessments and tracking, giving management oversight and reducing manual involvement.

Closing thought

The consultation revealed a strong appetite for reform, alongside the inherent complexity of achieving meaningful global alignment. For mobility teams, preparedness remains essential: even if simplification lies ahead, robust data, agile governance, and proactive risk management will continue to underpin successful global working strategies.

Contact us

If you’d like to discuss how these changes affect your international workers, please reach out to your Vialto Partners contact, or connect with:

Amanda McIntyre
Global lead Remote Work

Claire Pepper
EMEA lead Remote Work

Sanjita Samal
Americas lead Remote Work

Ben Neumann
APAC lead Remote Work

Louise Nicholls
Remote Work policy and governance

Kate Lind
Remote Work technology

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