Mobility Matters

There's nothing "remote" about personal income tax and social security when working remotely or teleworking.

December 2021 | by Daida Hadzic, Mobility & People, Meijurg & Company, The Netherlands

More than a year and a half ago, Europe implemented lock-down measures to control the spread of COVID-19. The functioning of the European Union (EU) single market1 with free movement of people and services was impaired by national measures aimed at containing the spread of the pandemic. Economies in Europe—and around the world—took a hit. To help redress the impact of the pandemic on the economy and the labour market, the EU Commission called for a coordinated response to the economic recession. It encouraged the EU member states to focus on economic stability, social fairness, environmental sustainability, and productivity and competitiveness.2

As governments and businesses, non-profits and educational institutions, and others, attempted to confront the crisis, offices and schools shut down, and workers and students were sent home. In this context, teleworking3 has come to be an essential aspect of business continuity during the COVID-19 pandemic. The EU Commission stressed that “teleworking productivity”4 plays a significant role in stepping out of an economic recession and into economic growth—the adaptation to digitalisation, e-commerce, e-government, home-work arrangements, teleworking, etc., on a larger scale would affect economic productivity positively.5

The positive effects of teleworking on the economy were not the only positive effects that surfaced during lockdown. Many employees realised that a high degree of flexibility in working arrangements gave them a possibility to achieve better work-life balance and combine their professional and personal aspirations in a more effective way. 

Flexible working arrangements that include employees having flexible working places—and perhaps even having more than one (permanent) place of work—can be seen as a central element in the digital economy and economic growth. 

If teleworking is so advantageous and important for the growth of economies, how does a multinational company implement a successful strategy for teleworking in the first place? Is teleworking a viable option at all? How should that multinational address the challenges of taxation and social security for itself and for its teleworkers?

Is the evolution toward teleworking and other flexible working arrangements compatible with taxation and social security? Have national tax authorities and governments taken note of this development for purposes of designing their national tax and social security policies?

These are some of the questions that will be discussed in this article. 

Dynamics of Tax and Telework

There are several considerations with regards to the interplay of taxation and teleworking in this digital economy era. There is limited public discourse that deals with the impact of teleworking on personal income tax and social security post-COVID-19. Public debate tends to focus more on the current situation and the continuing leniency of authorities (more on this below) while restrictions on movement of people are still in place and the state of the health emergency is still in force. 

However, taxing multinational companies in jurisdictions where they have physical and/or digital presence has come to the fore and grabbed increasing attention. In addition, if we then consider that corporate income tax accounted for approximately 10 percent of total tax revenues in OECD countries in 2018 and personal income taxes accounted for about 23.5 percent of total tax revenues,6 it seems inevitable that the attention of governments, international institutions, and fiscal experts should also include an in-depth look into the dynamics of personal income tax in the digital economy in general and teleworking in particular. 

Finally, if the effects of teleworking on personal taxation and social security result in financial disadvantages, less social protection for individuals—that is, employees—and their families, more bureaucracy, and lower levels of compliance, then the success of “teleworking productivity” is in jeopardy. (“Teleworking productivity” is the terminology used by the EU Commission in its report of recommendations.)

Telework , Before, During, and After COVID-19

(Source: Eurostat, Employed persons working from home as a percentage of the total employment, by sex, age and professional status (%))

Share of employed persons usually working from home

 

Teleworking is not a new phenomenon—COVID-19 has merely accelerated teleworking, making it an acceptable and attractive form of working to many employees. Teleworking prior to COVID-19 was generally an occasional event rather than a permanent working pattern in most cases. In fact, in 2019 on average only 5.4 percent of employees in the 27 member states of the EU (EU-27) usually worked from home, a share that has remained constant since 2009.

As illustrated in the graphs above, it should be noted that the variation between the countries is striking. While 14.1 percent of employees usually worked from home in 2019 in The Netherlands and Finland, less than 1 percent of employees usually worked from home in Romania and Bulgaria, and less than 2 percent were recorded for Hungary, Cyprus, Croatia, and Greece.8 Expectedly, the percentage of people usually working from home grew in all countries noted in the graph from 2019 to the first year of the coronavirus pandemic in 2020. 

Jobs Done Remotely 

As the new reality of teleworking during lockdown was sinking in across the globe and discussions about the benefits and challenges teleworking brings about, it became practically commonplace to spot headlines where companies announce that employees will work remotely as a part of a new company policy; that employees will be given a choice to work wherever they want.9 This is often linked to the benefits of remote working such as flexibility to organise work, work-life balance, and less time spent on commuting, as well as, clearly, safeguarding public health. 

Research done in this field indicates that 31 percent of jobs in Europe10 and 37 percent of jobs in the USA11 can be done remotely. If we now remind ourselves that prior to COVID-19, on average 5.4 percent of employees in the EU-27 usually worked from home and if we assume that around 1/3 of jobs can be done remotely, there seems to be a significant unutilised potential of making telework a permanent part of business. 

Further, it should not be ignored that the suitability of teleworking differs between business sectors, family/societal circumstances, prevalence of public transport, company sizes, etc. Teleworking tends to be more suitable for sectors like technology, finance, and pharmaceuticals, and less suitable for sectors such as transport, retail, hospitality, construction, and manufacturing.

Growing numbers of employees have developed an appetite to work remotely. For example, a job search site in the USA, Flexjobs, finds in its survey of more than 4,000 people that 65 percent of respondents want to become full-time remote employees post-pandemic, while 31 percent prefer a hybrid work arrangement with some days in the office and some days remote.12 Cisco Systems surveyed 10,000 people across 12 markets in Europe, the Middle East, and Russia for its “Workforce of the Future” research to find that 87 percent wanted the ability to choose where, how, and when they work, even though only 5 percent of those surveyed worked from home most of the time before the lockdown.13

In the beginning of the lockdown teleworking from another jurisdiction was attractive mainly to employees who had a connection to that jurisdiction such as a family connection or because it is a country of their origin. Now, a year and a half later working remotely from another jurisdiction is interesting to many who can do their work digitally. Roughly, teleworking is increasingly interesting in the following situations: 

  • teleworking as an extension of one’s holidays,
  • teleworking for one to three months annually in another jurisdiction, 
  • teleworking more than six months (permanently) in another jurisdiction.

Spotlight on Tax

There are several aspects to the shifting tax base occurring during the COVID-19 pandemic that deserve highlighting. Generally, the jobs suited for remote work in other jurisdictions are likely to be found on the higher end of income scales, and more highly remunerated employees tend to be digitally skilled and more ready to work remotely. The EU Commission pointed to the fact that the benefits of remote work are not available to unskilled or untrained employees,14 who are usually paid lower wages. 

If we assume that remote work in other jurisdictions is more suited for skilled employees in usually higher-paid jobs, and that these employees will become even more mobile, this could lead to shifts in the personal income tax base. Applying these assumptions in actual examples, some experts predict that states could potentially suffer substantial loss of tax revenues in future.15

It is extremely difficult to discern any indication about how tax authorities and governments intend to approach this challenge after COVID-19. The unpredictability of the legislative landscape for remote work in jurisdictions makes it almost impossible for employers to design long-term policies for remote working. This can lead to frustration for employers and employees (and their professional advisers) because they cannot establish any stable longer-term flexible working arrangements. We are currently seeing employers limit teleworking from another jurisdiction, typically to four weeks and often as an extension of an employee’s holidays. This is likely done with an assumption that such a time limit has a low risk of triggering liabilities in the host country and that a risk of an employee having to contact local authorities -- e.g. for health-care -- and thereby risking the local authorities discovering remote work is low during a four-week period. 

Another factor in respect of there being a low risk of triggering non-compliance for work done remotely in another jurisdiction is that currently, many governments continue to show leniency. When employees cannot access their usual working place, certain authorities have taken the position that, in some working situations, work in another jurisdiction does not lead to changes in the employee’s or the employer’s tax and social security situations16. This has revealed a certain awareness and acknowledgment of the exceptional times we are operating in and injected a certain “stability” in the tax situations of “displaced” employees and remote workers. It is not unreasonable to wonder though how long this will last. 

In some recent reporting, we have learnt of New York tax authorities targeting individuals who claim to have left the state during the COVID-19 pandemic—the aim being to collect income tax revenue.17 How long before we start to see similar actions in Europe? 

Even though there seems to be motivation for governments and tax authorities to engage in discourse regarding taxes on personal income and social security post-COVID-19, it can be argued that is not the case. Instead, we are observing various countries competing for skilled labour by launching targeted initiatives, such as visas for so-called “digital nomads” and special tax regimes that allow a lower tax rate on personal income for highly-skilled labour. 

These programs can be problematic. Special tax regimes that provide for lower tax rates on personal income, typically for high-income earners, increased from 5 to 26 from 1995 to 2020 in the EU, a tax cost of at least EUR 4.5 billion annually and more than 200,000 beneficiaries. These numbers could be significantly higher as some EU countries did not provide sufficient data to make a more precise calculation. The EU Tax Observatory identifies in its study that among the most aggressive special tax schemes are Cypriot, Italian, and Greek high-income schemes and the pension schemes of Cyprus, Greece, and Portugal.18 Such preferential treatment can influence mobility, and affect where mobility occurs, since countries that do not have such options for bringing in lower taxation may be left behind as people choose where to work. Furthermore, the most aggressive regimes seemed to have been introduced only recently. Greek and Italian lump-sum tax regimes on foreign-sourced income allow individuals a tax rate reduction by over 50 percent for taxable incomes of at least EUR 500,000 for periods of over eight years without a requirement for a real economic activity.19

Among the least aggressive regimes according to the study of the EU Tax Observatory are the Austrian artists and athletes schemes and the Finnish researchers scheme that are intended to attract certain professionals and are primarily short-term schemes.20 

The EU member states have introduced special tax regimes to attract personal income-taxpayers. However, the EU Tax Observatory highlights that these schemes are problematic as they target the highest-income taxpayers which directly undermines the progressivity of tax systems and inflict revenue losses on other countries by attracting taxpayers who would not have moved their tax domicile in the absence of such regimes 21. It may be expected that the number of special tax regimes will continue to increase and the countries will at some point be obliged to look at the effects of uncoordinated, unilateral and highly-competitive approaches to tax policy for individuals in terms of the tax base and labour mobility. 

The EU Tax Observatory recommends that some of the initiatives in respect of corporate taxation be considered for personal income taxation. For example, assessing and identifying aggressive tax regimes with a view to abolishing such regimes is one option.22

While several EU members states have introduced special tax regimes to attract personal income-taxpayers, the member states may decide to consider taxing expatriates who move their tax residency to another country. These former tax residents would be taxed on income in the country of their original tax residence for a number of years, a form of “tax quarantine.”23 It is too early to determine what we can expect from the member states in the future when considering taxation on personal income; but it is reasonable to expect that we could see significant changes to taxation of personal income, either unilaterally or as a coordinated approach by the member states. Whatever happens it will likely have a significant effect on the mobility of workers, especially those on the highest end of the earnings scale. 

Administration

Another interesting aspect of remote working is the role of the employer. Increased mobility due to teleworking can lead to diminishing the role of employers as the party responsible for withholding and paying taxes on wages. A decrease in withholding taxes is conceivable, as administrations’ assessments of whether a person is self-employed are increasing.24 

In other words, the changes in employees’ workplace jurisdictions, as a result of an increase in teleworking, may also lead to a shift in administrative liability to withhold and pay tax on wages from the employer to the individual.

Moreover, the physical detachment between employer and employee might lead some to no longer identify as employees, but rather as self-employed agents. Marc Zuckerberg, CEO of Facebook, predicts that half of the company’s employees will be working remotely within the next five to ten years, and at the same time he states that employees can expect adjustments to their salaries if they change their location.25 This is an interesting position to take, because it would, theoretically, reduce financial incentives that might motivate an employee to consider moving to a different jurisdiction. Moreover, it would not simplify administration of compensation and benefits, payroll, and so forth. 

It will be interesting to see if and how other companies will implement adjustments to compensation packages in their teleworking policies when employees relocate to a jurisdiction with lower taxation, lower cost of living, etc. It will be equally interesting to see how this “equalisation” will be received by the employees in an environment where there is global competition to attract talent. 

Social Security

It is important to consider social security contributions when discussing tax revenues on personal income. Social security contributions (sometimes called “social security tax”) are in most countries a shared financial burden between employer and employee, and they may cover compulsory insurances such as social pension, health insurance, sickness benefits, etc., for employees and their families. Social security contributions may provide individuals with benefits at any stage of life.26 

Perhaps it is because of the “quid pro quo” principle in most social security systems that the share of social security contributions is higher in most of the European Economic Area (EEA)—which includes the 27 EU countries plus Iceland, Liechtenstein, and Norway—than the share of tax revenues that comes from direct taxes.27 Levels of social security contributions vary from country to country, as do the levels of benefits and social security protection.

What Is the Potential Impact of Teleworking on Social Security? 

In the EEA countries and Switzerland, employers and employees cannot choose in which country they are covered by social security. Instead, the competent country for social security is determined through a uniform set of coordination rules.28

Recently, a couple of EU member states have taken an approach that when an employee works, for instance, for four weeks in another jurisdiction in a one-off arrangement, both employer and employee are liable to social security in the host member state. Given this author’s experiences with several authorities on certificates of coverage matters, authorities in certain of these countries have made an interpretation of the coordination rules that categorise working remotely in another jurisdiction as a separate form of working that is not covered by an exception rule on temporary posting. Here, they argue that the EU coordination rules cannot apply to situations in which an employee relocates temporarily without a specific business reason for them working in that specific location. 

This line of reasoning is familiar from treaties on social security, e.g., between an EU member state and a non-EU member state. However, within the scope of existing EU legislation, this interpretation does not seem to find support in the legislation or EU case law, but such practices in these few member states continue all the same. It is therefore possible that we will see a case in which the home country refuses to issue a certificate of coverage to an employee who is working remotely in another member state before the European Court of Justice. 

This situation with the categorisation of teleworking in another jurisdiction as a separate form of working that is not in the scope of the posting provision in EU legislation becomes increasingly perplexing when we learn, based on experiences and observations, that the same authorities issue certificates of coverage to employees working remotely in another jurisdiction when this work is categorised under the provision for work in two or more member states (multi-state working). However, the application of the provision for multi-state work does not come without challenges.

A working situation that has become much more widespread during the pandemic is that in which the employer is in one country and the employee is resident in another country. The EEA coordination rules for social security state that an employee who works less than 25 percent in the country of residence is covered by social security in the country where the employer is situated. However, if an employee is working at least 25 percent of the time in the country of residence, the employee is covered by social security in the country of residence.

This may be administratively burdensome, as the employer must register and comply with the social security rules in the country of the employee’s residence, a process which is often complicated and costly, and may result in non-compliance. 

Temporary Relief Measures Due to COVID-19 and the Future 

Due to COVID-19 restrictions in the EU and the inability to conduct one’s work as usual, many frontier workers29 and employees who occasionally worked from home (less than 25 percent) pre-pandemic are now working most of their time remotely and from home, in a different jurisdiction than their employer. This means that social security should shift from the country of their employer to their country of residence. However, employers and employees for the time being can rely on the temporary measures EU countries have implemented that allow remote work in the country of residence to exceed 25 percent of the employee’s time without triggering changes in their social security position, unless these changes to the working arrangement are meant to be permanent.30

The leniency by the social security authorities in the EU to not change the country that is competent for social security when working patterns change is based on the fact that the global pandemic has prevented workers from moving freely. Because remote work is not a choice but is instead necessitated by health emergency and pandemic control measures, the change in one’s usual work location to a different (remote) location would not generally result in changes to the applicable legislation for social security. However, if employees choose to work from their home countries in increasing numbers, countries may question whether the 25-percent threshold continues to be appropriate. 

Many perceive the 25-percent threshold not to be practical. Twenty-five percent of work can be organised in various ways, but it would be an unusual pattern for employees to work a full week from home and three weeks from the office. It may therefore be more relevant to look at the 25-percent threshold on a daily basis. If an average full-time employee works eight hours per day, five days per week, 25 percent amounts to one day and a couple of hours of the second working day. If we assume that in general one full working day amounts to 20 percent of work, then a more appropriate threshold could be 40 percent. If an employee worked up to 40 percent in the country of residence, social security in the country where the employer is located would continue to apply. 

A threshold of 40 percent would allow for a higher degree of flexibility than a threshold of 25 percent, and it is easier to calculate and comply with. As the pandemic continues and work patterns continue to change, we may see EU member states elevate the issue to the EU level, to consider reviewing the coordination rules from a long-term perspective. 

If we consider countries outside the EU, there are similar challenges in bilateral social security agreements (or “totalisation agreements”), which may need to be reviewed and adjusted to address the ways people work in a cross-border context at present and (presumably) in future. For example, in the USA, an employee cannot maintain coverage under U.S. social security if he or she initiated the relocation, and it is not substantiated with business reasons―if an employee in the USA requests to work remotely for a couple of months from Portugal for personal reasons, for example.

We have already mentioned that in some of these bilateral treaties teleworking in the other jurisdiction as a one-off arrangement does not allow coverage under social security in the home country. It would be helpful if the authorities engaged in a dialogue to review this position and consider changing it to modernise the treaties and accommodate developments in the labour market. The objective of these treaties is to remove obstacles to mobility between the countries and provide continued protection when work in other jurisdiction is of a temporary nature. 

However, another challenge in these treaties is that very few of them describe a situation in which an employee works in both countries in alternance, what we know as multi-state work from the EU legislation. At the time many of these treaties had been concluded it was not relevant to consider a situation in which an employee could work simultaneously in both countries as usual, but developments in technology and infrastructure are making it possible -- and commonplace -- for employees to work in both, e.g., in Germany and the USA in alternation. Therefore, it may be worthwhile for countries to reconsider their social security agreements to assess whether they are adequate for the current and future labour markets, as well as whether they still support mobility, as was their initial intention. 

It will be interesting to follow this topic, because if teleworking in another jurisdiction becomes categorised as a form of working that is not subject to the coordination rules on social security, it could potentially restrict the free movement of employees and prevent businesses and employees from reaping all the potential benefits of remote working, from optimising and growing a business to improving work-life balance and employee satisfaction. 

Conclusion

Teleworking existed before and it will exist after COVID-19. The digital economy and digital infrastructure are expanding and facilitating opportunities for mobility, making telework accessible to a wider pool of employees who see value in relocating and working remotely from one work location or several locations. 

As discussed earlier, an increase in mobility can lead to an erosion of the personal income tax base as employees move their tax residence and/or convert their employment status into self-employment. Further, the increased mobility of employees can lead to lower levels of compliance as complexity and administrative burdens increase. Finally, the effects of preferential tax regimes and similar initiatives should also be analysed from a regional perspective in order to understand their impact on the global labour market. Before we experience significant unilateral initiatives by the member states to obstruct the effects of aggressive tax regimes on personal income in some member states, it is desirable that the member states find a coordinated and balanced approach to dealing with taxation on income for mobile employees. 

Rules for social security, much like personal income tax, do not seem to be adequate for a future labour market that is characterised by more mobility and flexibility in work arrangements. Current temporary leniency and relief measures to avoid changes in the country competent for social security are likely to end once the “state of health emergency” is deemed to have concluded. If teleworking continues at a similar level, this may well lead to changes in social security for large numbers of people. 

Unlike bilateral treaties dealing with taxation on personal income, it is possible to fairly easily update the rules on social security in a single legal instrument for EEA countries and Switzerland—the EU Regulation for social security. Therefore, there is an opportunity now to review the rules that coordinate social security between countries and update them to fit the current and future labour markets. Multinational companies have plenty of experience with these matters and knowledge about how the rules interact in combination with different countries, nationalities, business sectors, worker skills levels, etc.

With so many questions regarding how legislators and governments intend to regulate the legal landscape for mobility post-COVID-19, in-depth dialogue with relevant stakeholders should be initiated. EU institutions, like the EU Parliament, and especially the European Commission, could play important roles in motivating and coordinating such dialogue. As telework and remote work arrangements—and in many cases a hybrid form of in-office/telework—become popular and continue apace, it is so important that governments and multinational institutions take proactive steps to meet cross-border businesses and their workers where they are and, no less importantly, reinforce their own revenue bases. 


Footnotes

Footnotes:
1 The EU Single Market refers to the EU as one territory, without any internal borders or regulatory obstacles to free movement of goods and services. 
2 European Commission, “Communication from the Commission to the European Parliament, the European Council, the Council, the European Central Bank, the European Economic and Social Committee, the Committee of the Regions and the European Investment Bank“ (20 May 2020). 
Telework entails the use of information and communication technologies such as laptops, tablets, smartphones and desktop computers for work that is done outside the company premises. Remote working, working from home, work anywhere and other terms used in daily language usually refer to the same things as telework.
European Commission, “Communication from the Commission to the European Parliament, the European Council, the Council, the European Central Bank, the European Economic and Social Committee, the Committee of the Regions and the European Investment Bank“(20 May 2020), p. 14. 
5 Ibid.
OECD: Global Revenue Statistics Database at https://www.oecd.org/tax/tax-policy/global-revenue-statistics -database.htm . Corporate tax revenues refer to taxes on profits and gains of corporations and personal income tax revenues refer to taxes on income, profits, and capital gains of individuals. 
7 Eurostat, “Employed persons working from home as a percentage of the total employment, by sex, age and professional status (%)”( 2 June 2021).
8 Ibid.
9 Z. Tayeb, “From permanent work-from-home models to full-scale returns, companies like Amazon, Twitter, and Goldman Sachs are pursuing different office policies as restrictions ease,” Insider (online), 16 June 2021. See: https://www.businessinsider.com/remote-working-divide-amazon-twitter-goldman-spotify-hybrid-offices-2021-3 . By clicking on this URL, or any of the URLs provided in footnote 9, you are leaving the KPMG website for an external site that KPMG is not affiliated with, nor is KPMG endorsing its content. The use of the external site and its content may be subject to the terms of use and/or privacy policies of its owner or operator.
M. DeGeurin, “Big Tech’s struggle to bring its workers back to the office,” eMarketer (online), 25 June 2021. See: https://www.emarketer.com/content/big-tech-s-struggle-bring-its-workers-back-office.
J. Kelly, “The Real Reasons Why Companies Don’t Want You To Work Remotely,” Forbes (online), 17 August 2021. See: https://www.forbes.com/sites/jackkelly/2021/08/17/the-real-reasons-why-companies-dont-want-you-to-work-remotely/?sh=902dea77fb31. 
K. Stoller, “Never Want To Go Back To The Office? Here’s Where You Should Work,” Forbes (online). See: https://www3.forbes.com/leadership/never-want-to-go-back-to-the-office-heres-where-you-should-work-ifs-vue-mn-wnb/?slide=2.
S. Mukherjee, “Nokia to allow employees to work remotely for three days a week,” Reuters (online), 22 June 2021. See: https://www.reuters.com/technology/nokia-allow-employees-work-remotely-three-days-week-2021-06-22/.
E. Courtney, “30 Companies Switching to Long-Term Remote Work,” Flexjobs (online). See: https://www.flexjobs.com/blog/post/companies-switching-remote-work-long-term/ .“Le travail à distance dessine-t-il le futur du travail?” La Fabrique de l’Industrie (online). See: https://www.la-fabrique.fr/fr/publication/le-travail-a-distance-dessine-t-il-le-futur-du-travail-2/.
A. Cerezo, “Las empresas plantean el modelo híbrido en la vuelta a la oficina,” ABC-Economía, 31 agosto 2021. See: https://www.abc.es/economia/abci-empresas-plantean-modelo-hibrido-vuelta-oficina-202108290144_noticia.html.
A. Chanthadavong, “Switching it up: How companies managed remote working during a pandemic,” ZDNet (online), 28 March 2021. See: https://www.zdnet.com/article/switching-it-up-how-companies-managed-remote-working-during-a-pandemic/.
D. Adams, “4 in 5 Australian businesses say that remote work is here to stay long term, even as offices reopen nationwide,” Business Insider-Australia (online, 30 April 2021. See: https://www.businessinsider.com.au/work-from-home-australian-bureau-statistics-data-2021-4.
S. Jacob, “95% Indian firms to continue with remote work for next two years: Survey,” Business Standard (online), 14 July 2021. See: https://www.business-standard.com/article/companies/95-indian-firms-to-continue-with-remote-work-for-next-two-years-survey-121071400432_1.html.
D. Madhok, “TCS employs more than 500,000 people. It’s ready to ditch office life for many in India,” CNN Business (online), 19 August 2021. See: https://www. cnn.com/2021/08/15/economy/tcs-india-it-remote-intl-hnk/index.html .
10 T. Boeri, A. Caiumi, and M. Paccagnella, “Mitigating the work-safety trade-off,” Covid Economics (Issue 2, 8 April 2020). 
11 J. Dingel and B. Neiman, “How Many Jobs Can Be Done at Home?” National Bureau of Economic Research (Working paper 26948, April 2020).
12 R. Pelta, “FlexJobs Survey: Productivity, Work-Life Balance Improves During Pandemic,” Flexjobs (online). See: https://www.flexjobs.com/blog/post/survey-productivity-balance-improve-during-pandemic-remote-work/ . By clicking on this URL, you are leaving the KPMG website for an external site that KPMG is not affiliated with, nor is KPMG endorsing its content. The use of the external site and its content may be subject to the terms of use and/or privacy policies of its owner or operator.
13 Cisco Systems, “Executive Insight Report: A new perspective on the modern workplace.” See: https://www.cisco.com/c/dam/en/us/solutions/collateral/collaboration/ow-flash-survey.pdf . By clicking on this URL, you are leaving the KPMG website for an external site that KPMG is not affiliated with, nor is KPMG endorsing its content. The use of the external site and its content may be subject to the terms of use and/or privacy policies of its owner or operator.
14 European Commission, “Communication from the Commission to the European Parliament, the European Council, the Council, the European Central Bank, the European and Social Committee, the Committee of the Regions and the European Investment Bank“ (20 May 2020).
15 M. de la Feria, “The Impact of Digitalisation on Personal Income Taxes,” British Tax Review, Issue 2, pp. 154-168, (27 April 2021).
16 See, for example, GMS Flash Alert 2021-279, 15 November 2021, a publication of KPMG International. 
17 D. Borak, “New York Blitzes $100,000 Earners with Remote-Worker Tax Audits,” Bloomberg Wealth (online), 11 August 2021. See: https://www.bloomberg.com/news/articles/2021-08-11/new-york-blitzes-100-000-earners-with-remote-worker-tax-audits. By clicking on this URL, you are leaving the KPMG website for an external site that KPMG is not affiliated with, nor is KPMG endorsing its content. The use of the external site and its content may be subject to the terms of use and/or privacy policies of its owner or operator.
18 The EU Tax Observatory is an independent research center funded by the EU that conducts and disseminates innovative studies on taxation and stimulates exchanges between the scientific community, civil society, and policymakers. https://www.taxobservatory.eu/. EU Tax Observatory, “New Forms of Tax Competition in the European Union: An Empirical Investigation,” November 2021, page 18, https://www.taxobservatory.eu/wp-content/uploads/2021/11/EU-Tax-Observatory-Report-3-Tax-Competition-November-2021.pdf. 
19 Ibid., p.16 of the report.   
20 Ibid.,p.16 of the report.
21 Ibid., pp. 18, 37 of the report.  
22 Ibid., page 34 of the report.
23 Ibid., page 35 of the report.
24 M. de la Feria and F. Maffini, “The Impact of Digitalisation on Personal Income Taxes,” British Tax Review, Issue 2, pp. 154-168, (27 April 2021).
25 S. Rodriguez, “Zuckerberg says employees moving out of Silicon Valley may face pay cuts,” CNBC (online) (21 May 2020). See: https://www.cnbc.com/2020/05/21/zuckerberg-50percent-of-facebook-employees-could-be-working-remotely.html. By clicking on this URL, you are leaving the KPMG website for an external site that KPMG is not affiliated with, nor is KPMG endorsing its content. The use of the external site and its content may be subject to the terms of use and/or privacy policies of its owner or operator.
26 For example, in some countries, employers are entitled to claim sickness benefits from a public authority which they use to cover (some of) salary cost for employees on sick leave. 
27 See European Commission, “Taxation Trends in the European Union,” (Eurostat) (2021 Ed.) at: https://op.europa.eu/en/publication-detail/-/publication/d5b94e4e-d4f1-11eb-895a-01aa75ed71a1/language-en .
28 Regulation (EC) for coordination of social security no. 883/2004, Regulation (EC) for administration of Regulation for coordination of social security no. 987/2009.
29 Frontier workers in this context describe persons who reside in one country and travel every day to work in another country.
30 For related articles on this topic in GMS Flash Alert, see issues 2021-236 (15 September 2021), 2021-193 (2 July 2021), 2021-184 (25 June 2021), and 2020-492 (11 December 2020), a publication of KPMG International.