World Economic Forum: The Good Work Framework

World Economic Forum: The Good Work Framework

In collaboration with the World Economic Forum (WEF), The Good Work Framework: A new business agenda for the future of work shares insights into a framework to enable good work that includes five pillars with associated goals to address people issues arising from the trends. Five key issues have emerged that need to be addressed to ensure better work for workers and employers alike: (1) volatility in wages and the cost of living; (2) divergence on the demand for flexibility; (3) silent pandemic in well-being; (4) an erosion of diversity, equity and inclusion (DEI) gains; (5) and the need for a reskilling revolution.

World Economic Forum: The Good Work Framework Report

Revolutionalize Your Global Mobility Program

Revolutionalize Your Global Mobility Program

2023 is shaping up to be a significant year for global mobility programs. Seismic changes to the mobility environment have been precipitated by the pandemic, geo-political tensions, societal changes, the environmental crisis, and economic headwinds.

As we enter a new year, many companies are recognizing that fundamental change is needed for their mobility programs to remain relevant and effective. So, what should companies do to ensure their program is fit for purpose in the mid-2020’s? Here, we have highlighted five ways in which we believe companies can revolutionize their mobility program:

Revolutionize Your GM Program

View Program

Remote Workers – potential changes to the UN model tax treaty

Remote Workers – potential changes to the UN model tax treaty

Insight: The UN’s Tax Committee is considering an addition to Article 15 of its model treaty, targeted at the employment income of remote workers

The growth of remote working arrangements has led to questions regarding the fair apportionment of taxing rights under existing treaties. The UN’s Tax Committee has been considering the question of remote worker taxation and whether changes to its model convention are required. With the 27th Session of the Committee of Experts on International Cooperation in Tax Matters taking place in Geneva between 17-20 October 2023, papers have now been published outlining the UN’s proposed Article 15(4) and further considerations on the topic.

Whilst it is possible that the UN’s proposed wording will iterate in the coming months, the current proposal would enable the employer’s State of residence to exercise additional taxing rights over the income of an employee who is working remotely in the other Contracting State.

The following draft Article 15(4) is intended for discussion during the UN Tax Committee’s 27th Session on 18 October 2023, with a view to its submission for final approval at the 28th Session next spring. Furthermore, draft accompanying Commentary will be developed for initial consideration at the 28th Session of the Committee.

Notwithstanding the provisions of paragraphs 1 and 2, remuneration derived by a resident of a Contracting State in respect of an employment exercised in that State or in a third State may be taxed in the other Contracting State to the extent that the remuneration is paid by [or on behalf of] an employer who is a resident of that other State.

A proposed addition to Article 23B would also ensure that double taxation should be prevented by way of a credit being granted by the State of the employer, to the extent that employment income is taxed in both States by virtue of Article 15(4). Therefore the additional taxing rights created by the proposed amendments to the model Convention operate, effectively, as a top-up tax for the employer’s State of residence.

It is welcome and encouraging to see the UN Tax Committee taking the initiative in its response to the growth in remote working arrangements and the plethora of tax questions it raises. However, at this stage the proposed paragraph arguably raises more questions than it resolves.

The taxation of remote workers was initially considered by the UN’s Tax Committee at the 26th Session of the Committee of Experts on International Cooperation in Tax Matters, in March 2023. It was agreed that Workstream C on remote workers should continue as a stand-alone project, however, there was no clear consensus on the focus of the work.

Subsequent Sub-Committee meetings were held during the summer, providing greater definition to the UN’s thinking around the issue, with these discussions resulting in the publication of the papers found in Annex 4 and 5 of its report on The Digitalized and Globalized Economy, shared in advance of the 27th Session of the Committee.

The two papers consider a wide range of issues relating to remote work, including the taxation of directors, government officials and ‘digital nomads’, however the primary focus is the question of how to tax the employment income of remote workers and prevent the erosion of the tax base of the employer’s State of residence. This has resulted in the proposed addition of Article 15(4) referred to above.

Draft Article 15(4) – initial reflections

The UN Tax Committee’s current proposals are at an early stage. If they do progress, we would anticipate the wording of Article 15(4) to iterate in the coming months. Furthermore, inclusion as a paragraph in the UN’s model tax convention does not automatically mean it will become a feature of all future tax treaties.  Nevertheless, the UN’s proposals are noteworthy and may lead to further developments in the cross-border taxation of remote workers as their thinking evolves. Our initial reflections on the current draft can be found below:

Domestic taxing provisions

The UN’s proposal grants additional taxing rights to the State in which the employer is resident to the extent that the remuneration is paid by or on behalf of that employer, even if the employee concerned has never actually exercised their employment duties in that State. Non-resident employees are typically only taxed to the extent that employment duties are performed in a given country, so unless such countries alter their domestic legislation, draft Article 15(4) may have limited effect in practice. Of course, it is possible that countries may alter their domestic legislation to give broader scope to taxing non-residents, but that would run contrary to a general principle of residency-based taxation that a State does not tax individuals who have never performed employment duties in that location.

Winners and losers

One of the overriding problems with any measure to address the taxation of remote workers is that its likely popularity and effectiveness will be driven by the extent to which a Contracting State believes it will benefit from the measure. If the net inflow/outflow of tax revenue from remote workers is considered likely to be generally equal between Contracting States then the measure may gain acceptance, however, if instead there is a ‘Winner’ and a ‘Loser’ between the two parties, then adoption is far less likely. In the case of the proposed paragraph, granting additional taxing rights to the employer’s State of residence would seemingly favour more developed economies where an international employer would typically be resident, but would seemingly present far less upside for emerging economies with fewer employers whose employees work remotely.


The position regarding secondments may also be tricky to navigate in practice. If a secondee’s remuneration continues to be paid by their contractual employer back in their home country, does this mean that Article 15(4) would ensure that the home country continues to have taxing rights, notwithstanding the possibility that they are neither resident nor performing any duties in that country whilst on secondment? The application of the economic employer concept may resolve the position adequately in some scenarios (i.e. if it is determined that the ‘employer’ for treaty purposes is actually the entity for which the individual is working in their country of assignment then Article 15(4) would not apply), albeit not all countries apply the economic employer concept and so anomalous taxing positions may ensure.

Overseas branches

In a similar vein to the inadvertent impact on secondments, the draft paragraph would appear to apply even where the employee is working as an employee of an overseas branch, perhaps unintentionally giving the provision broader application than standard remote work scenarios. By way of illustration, would it make sense for an employee of the UK branch of a Japanese bank to be subject to tax additionally in Japan despite living and working in London? Many would say not, so it would seem that the UN would need to give further consideration to scenarios of this nature and ensure that they are not affected by the proposed measure.

The UN’s timeline and next steps

The UN’s engagement with the growth in remote working and the tax challenges which it throws up is very welcome. However, the current proposals clearly demonstrate the practical difficulties in finding a way forward which works for the majority of Contracting States. It is to be hoped that these challenges can be resolved in time for the intended finalisation of the measures at the UN Tax Committee’s 28th Session next spring. In the meantime, we also await publication of the OECD’s scoping note on remote workers, which is expected before the end of the year and which should also explore the question of Permanent Establishment risks arising from remote work. There’s clearly more to come from the UN and OECD on the subject of remote work, though whether a workable consensus can be found on formal additions to their respective model conventions remains uncertain.

GME Report 2023 | Cutting Costs without Cutting Corners

GME Report 2023 | Cutting Costs without Cutting Corners

In this report we will assess the impact of the economic climate on Global Mobility, considering the importance placed on cost reduction, and investigating ways in which companies are looking to reduce costs and the policy areas targeted.

Cost Cutting Report

How is Immigration Policy Adapting in the Face of Growing Skills Gaps and the War for Talent?

How is Immigration Policy Adapting in the Face of Growing Skills Gaps and the War for Talent?

How is Immigration Policy Adapting in the Face of Growing Skills Gaps and the War for Talent?

Sonya B. Cole, Fragomen Knowledge Group

As adapted from Fragomen’s Worldwide Immigration Trends Reports

The world is reeling from a confusing paradox: though unemployment rates are low in many countries, job positions are still going unfilled at record levels. The worker and skills gap are taking a toll on global economies, and immigration policy has been at the forefront as a solution to this problem in many countries.

Many immigration policies adopted starting in Q2 2022 included streamlined entry processes, reduced administrative in-country requirements, easier-to-use and more responsive online systems, and other legal mechanisms to encourage the entry of skilled immigrant workers. Investor permits, entrepreneur permits and digital nomad permits grew in number and in popularity.  

In the last few months, countries that are continuing to struggle to fill local skills gaps are increasingly rolling out special visa pathways that:

  • Offer entry without an employer sponsor;
  • Allow applicants to look for work during their stay;
  • Focus on individuals with extraordinary abilities or talent;
  • Focus on skills and experience rather than education or degree requirements; and
  • Provide the opportunity to match skills missing in the local population with displaced individuals through complementary pathways.

The Economic Downturn Created a Need for More Skilled-Based Immigration Programs

Though responsiveness in immigration policy to economic conditions is not a new phenomenon, the relatively quick turn to skills-based immigration programs in many countries certainly is.

With the spike in quit rates and industry-switching amid the COVID-19 pandemic, in the 2022 edition of the Worldwide Immigration Trends Report, we projected a free-agency era, with bargaining power residing in the worker’s court. This phenomenon pressed governments and employers alike to adjust traditional policies and protocols that no longer suited the reality of the labor market.

Though the employee-centric business model did in fact gain popularity, many employers’ priorities turned a corner as inflation and interest rates soared in Q1 2023. Hiring strategies and mobility planning across industries and regions were heavily impacted by the economic downturn, and many well-publicized and widespread layoffs occurred in the last two quarters.

Now that layoffs have seemingly slowed down, many employers are growingly realizing that by embracing experience and skills and focusing less on specific education levels, positions are more likely to be filled internally, saving companies costs and administrative burdens of hiring. The applicant pool is also wider with skills-based hiring, making it easier to find workers in a time of low unemployment rates.

In response to this tumultuous employment environment (stakeholders have been growingly voicing their concerns to governments in public hearings and commentary periods for legislation), many countries are bridging the gap between experience and education to attract skilled workers. Key policy include:

  • In Canada, the Global Talent Stream offers a three-year temporary visa to highly-skilled workers, requiring experience but no academic background; processing times are expedited, and successful candidates generally receive their visa in 10-14 calendar days. This program added 5,000 positions in 2021, prioritizing occupations in technology and engineering.
  • In Spain, the government introduced an experiential-based training system in 2021 to Spanish citizens, which includes the accreditation of professional skills through on-the-job training, allowing participants to tailor the program to their own goals and employment needs. This initiative is expected to upskill three million people over a four-year period; and although its focus lies on the professional growth of non-migrant workers, it serves as a promising model for potential visa pathways in order to boost international talent.

Who Else is Benefiting from the Skills-based Mobility Policies?

  1. Foreign national workers – Foreign workers themselves are benefitting from policies that place less emphasis on academic qualifications and procedural stringency, and instead, focus more on experiential value and fast-tracking application efforts. This is particularly important for tech workers, where the shortage is most keenly seen in many countries. Workers’ trending desire for skill-based experience is quickly aligning with the needs of employers and governments not only for enrichment but practical purposes. Multi-step regulatory processes are waning in the face of urgency.

“By 2030, there will be a global shortage of more than 85 million tech workers, representing $8.5 trillion in lost annual revenue.” (from 2019 International Monetary Fund Report)

  1. Countries losing skilled workers to brain drain. In a bigger context, the more foreign workers with skills there are in a foreign country, the more local workers they can train (especially in countries that couple skill-transferring and knowledge-sharing with the hiring of foreign workers – many African countries have such requirements). This is especially important for foreign nationals working with technology skills in emerging countries, where the effects of brain drain can be minimized through this practice, which can eventually improve a country’s economy.

What’s next?

All in all, the continued assessment for flexibility and change in both the workplace and governments is vital in the ongoing attempt to compensate for skill gaps and workforce shortages. Here are some trends we are expecting in 2023 that will attempt to resolve these issues:

  • Talent and population hoarding. Just as employers have begun to cling to highly-skilled workers following mass layoffs, we predict that immigration systems will follow suit with streamlined citizenship and permanent residence processes, more long-term residence initiatives for skilled individuals and extended dependent rights as a means to regain dwindling populations and mitigate brain drain.
  • Stringent application requirements to continue to subside. We expect governments to continue re-evaluating certain parts of their work authorization requirements and processes this year and beyond, in an effort to fast-track position filling and ease mobility across countries, employers and even industries. Alongside the emphasis on experiential value, this may look like reduced labor market testing steps or expedited employment sponsorship processes. The steer-away from restrictionism will also likely help reduce the continued immigration application processing delays that are lingering from COVID-19 backlogs.
  • Continued growth of online platforms. Online application system use and development by governments will grow as countries continue their outreach efforts to encourage migration to improve economic conditions. Online platforms make applying for entry and work easier and reduce in-person requirements, which is a draw for many travelers, especially those on short-term assignments.
  • Continuation of remote work and digital nomad initiatives. As assignment volume and associated costs continue to grow, we predict employers will increasingly use hybrid and remote work as a workaround to sending assignees to expensive metropolitan areas with housing crunches, high costs of living and other inflation impacts.

Read about these trends and predictions, among others, in Fragomen’s Worldwide Immigration Trends Report, available here: