Global Tax Experts Expose Hidden Risks in EoR/AoR International Workforce Strategies
David Ballew, CEO
The Promise of EoR/AoR Models
The comprehensive analysis exposes significant permanent establishment (PE) risks that many businesses unknowingly face when expanding internationally through seemingly straightforward employment arrangements.
Key Findings:
✅80% of companies using EoR/AoR services may be exposed to unexpected tax liabilities
✅Tax authorities are increasingly focused on "substance over form" in international workforce arrangements
✅Flexible work models create complex permanent establishment challenges
Critical Risks Highlighted:
🟣Expanded global tax enforcement across over 100 jurisdictions
🟣Sophisticated "virtual PE" concepts emerging in multiple countries
🟣Potential for retroactive tax assessments spanning 3-7 years
🟣Penalties ranging from 20-100% of unpaid tax liabilities
Country-Specific Enforcement Rankings
The research identifies the most aggressive PE enforcement jurisdictions:
1. India
2. Italy
3. France
4. Germany
5. Brazil
6. Australia
Recommended Strategies
Crossborder Solutions advises companies to:
✅Conduct comprehensive tax structure reviews
✅Implement robust functional separation
✅Restructure management and control mechanisms
✅Seek specialised international tax advisory services
Availability
The full article by David Ballew, 'Global Tax Experts Expose Hidden Risks in EoR/AoR International Workforce Strategies' is available here.
About Nimble Global
Since its founding in 2019, Nimble Global has established itself as a leader in international workforce compliance, delivering measurable results through data-driven methodologies and innovative technology. With headquarters in London and projects spanning 90+ countries, we combine local expertise with global reach to transform how organisations manage compliance. Our diverse team of specialists continuously develops new benchmarks and solutions, positioning us at the forefront of compliance and consultancy evolution.
Media Relations
Nimble Global
+44 20 8938 3414
compliance@nimbleglobal.com
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