GTN Global Mobility Tax Blog - News and Notes

Crafting Effective Payroll Solutions for a Global Workforce

Written by Mark Tirpak, EA | September 26, 2024

In today's interconnected world, the complexities of managing a global workforce extend far beyond cultural differences and time zones. One of the most intricate challenges facing multinational companies is the nuanced task of international payroll administration.

Picture this: You're a global mobility manager, and you've just wrapped up preparations for your top performer, Susan, to take on a strategic assignment from the United States to Germany. The logistics are in place—her household goods are en route, her work permit is secured, and her cost-of-living allowance is calculated. You're feeling confident until Susan poses a question that catches you off guard: “Will I be paid in dollars or euros?”

This seemingly straightforward inquiry unveils a web of considerations that many organizations overlook in the rush of international deployment. The choice of payment currency isn't merely about convenience; it can profoundly affect an employee's financial health, tax obligations, and overall satisfaction with their overseas experience.

In this article, we'll navigate the intricate terrain of international payroll administration, exploring the three primary methods of payroll delivery for globally mobile employees: Home country payroll, Host country payroll, and split payroll. We'll dissect the advantages and potential pitfalls of each approach, equipping you with the knowledge to make informed decisions that serve both your organization and your mobile workforce.

Home country payroll delivery

If a Home country payroll delivery method is used, your employee will continue to be paid from the Home country payroll in Home country currency, just as before the assignment.

Consider this scenario: Jenny, a software engineer from the US, is sent to Ireland for a 4-month training project. Despite the change in location, Jenny remains on the US payroll, receiving her salary in US dollars. She also maintains her enrollment in US health benefits and continues contributing to her US retirement plan.

This payroll delivery method is useful in several situations:

  • For employees embarking on brief international trips, i.e., business travelers
  • When managing short-term assignments that typically last up to 12 months
  • In cases of extended assignments (generally ranging from 1 to 5 years), provided the employee can continue participating in their Home country's social security system and/or benefits programs

Benefits of Home country payroll delivery

  • The employee can often remain enrolled in Home country benefits, and Home country social tax payments can typically continue to be funded through payroll.
  • The employee can receive funds in Home country currency. Any savings would not be subject to potential exchange rate fluctuations / risk.
  • The company can minimize changes to current payroll practices (i.e., limited or no administrative changes in pay delivery are necessary).

Drawbacks of Home country payroll delivery

  • The employee is receiving funds in Home country currency but may have to pay bills in Host country currency. They therefore bear exchange rate risk for expenses they have to pay locally in the Host country. Funds for their use in the Host country must often be converted (e.g., wire transfer, credit card), sometimes incurring costly fees.
  • Tax implications in the Host country typically do not directly correspond with compensation delivery. Accordingly, all or an attributable portion of earnings may need to be reported, and the related taxes paid, in the Host country (even if the employee's pay is delivered entirely from the Home country payroll).
  • Regarding medical benefits, business traveler or supplemental medical coverage may need to be purchased to ensure there are no gaps in coverage while they are in the Host country.
  • Amounts paid by or on behalf of the employee by their employer in the Host country (e.g., employee tax payments, housing, or other benefits and reimbursements) may need to be reported, and the related taxes paid in the Home country payroll.

Host country payroll delivery

If a Host country payroll delivery is used, your employee is no longer paid from the Home country payroll, but rather is paid 100% from the Host country payroll.

Consider this scenario: Wanda, a marketing executive from the US accepts a permanent position with your company's subsidiary in Brazil. As part of this transition:

  • Wanda’s employment with the US company is terminated and she transfers (permanently / indefinitely) to Brazil.
  • She is placed on the Brazilian payroll and receives her salary in Brazilian real.
  • Her participation in US benefits and retirement plans ceases.
  • She begins contributing to the Brazilian retirement plan and signs up for local health insurance and other benefits.

This payroll delivery method is particularly suited for permanent transfers, where the employee's relationship with their Home country employer is formally concluded. It's designed to fully integrate the employee into the Host country's employment structure and financial systems.

Benefits of Host country payroll delivery

  • The employee has funds in local currency to pay local expenses.
  • The employee is supported in their efforts to integrate into their new location; they are paid like other local employees.
  • The employee's benefit plan is locally appropriate.
  • The employee begins contributing to the retirement plan of their new country, consistent with their plan to remain in the Host country.

Drawbacks of Host country payroll delivery

  • If an employee is paid entirely from the Host country payroll and has previously terminated employment with the Home country company, they may (if they ultimately return to their Home country) lose out on some or all of their Home and/or Host retirement benefits. Providing a credit for years of service may help soften this blow.
  • The employee may have continuing financial obligations in the Home country (despite terminating their Home country employment) and will have to manage the cash flow and bear the cost or benefit of any exchange rate fluctuation for these Home-based expenses.
  • If the employee is an outbound US citizen, they have an ongoing (annual) US tax-reporting obligation, and potentially a US tax liability (and balance of tax due, if any required US tax payments have not been remitted). Participation in non-US pensions may result in US tax compliance complexities for the employee.

Split payroll delivery

If a split payroll delivery is used, a portion of the employee's pay is delivered from the Home country payroll, and a portion is delivered from the Host country payroll. The payroll delivery is thus "split" between two payrolls and two currencies.

Imagine this scenario: Helen, a US software developer, embarks on a 2-year project in France, with plans to return to the US afterwards. Her compensation is structured as follows:

  • Part of Helen’s salary is paid from the US company payroll in US dollars.
  • The remainder is paid from the French subsidiary's payroll in euros.
  • Helen continues to participate in the US social security tax system and her company's retirement plan.
  • She receives enough euros in France to cover her local living expenses.

This split payroll delivery method is particularly advantageous in two key situations:

  • For long-term assignees who maintain financial commitments in their Home country and intend to repatriate after the assignment.
  • In cases where Host country regulations mandate that a portion of an employee's compensation be paid locally.

Benefits of split payroll delivery

  • Depending on the scenario, the employee can enjoy uninterrupted participation in the Home country retirement plan and social tax system.
  • The employee receives funds in the currency they need for the country they are in.
  • The company can monitor cost of living in the Host country and can adjust the delivery split for changes in cost of living in the Host location if necessary or at the employee’s request.

Drawbacks of split payroll delivery

  • The employer takes responsibility to administer the "split" payroll using the balance sheet approach. Management of this can be challenging without (or even with!) established procedures.
  • The Home and Host country payrolls must be coordinated to ensure the payments are made correctly (and that duplicate payments are not made to the employee).
  • Compensation reporting and withholding is further complicated due to payments being delivered in multiple locations.
  • Shadow payrolls for the remittances of taxes may be needed in Home country, Host country, or both countries, creating additional payroll administration.

Other issues to consider when navigating the complexities of international payroll

When designing a payroll delivery strategy for international assignments, it's crucial to consider a myriad of factors:

Regulatory Landscape

Each country has unique regulations that can impact your payroll options. For instance:

  • Currency controls in some nations may necessitate limiting cash delivery in the Host country currency.
  • Immigration laws often dictate minimum salary requirements for work permits.

Tax Optimization

The structure and timing of remuneration and allowances can yield significant tax savings. For example, the length of an assignment may affect the taxability of certain benefits. Proactive planning before the assignment begins is key to maximizing these opportunities.

Reporting Requirements

While beyond this article's scope, it's important to note that each payroll method comes with its own set of compensation reporting challenges. A thorough evaluation of country-specific regulations and individual circumstances is essential for compliance.

Balancing Act

The ideal payroll delivery method must address both company and employee needs. Consider:

  • Protecting employees from currency fluctuations.
  • Ensuring access to appropriate currencies for expenses in both Home and Host countries.
  • Facilitating participation in suitable retirement plans.
  • Balancing employee convenience and regulatory compliance with the company's administrative capabilities.

Risk Management

Weigh the company's risk tolerance against the potential benefits of different payroll strategies.

Taking the next step

In today's dynamic global business environment, regularly assessing your organization's compensation delivery process is crucial. Implementing appropriate procedures and controls can streamline your international assignments and enhance employee satisfaction.

Are you ready to optimize your global mobility payroll strategy? Our team of experts is here to help you navigate these complex waters and find the best solutions for your organization.

To gain personalized insights and guidance:

  • Schedule a consultation: Set up a call with our experienced global mobility specialists. We'll discuss your specific challenges and provide tailored recommendations.
  • Explore our services: Visit our Mobility Tax Services page to learn more about how we can support your international assignment programs.

Together we can help determine the best payroll delivery solution for you.