Case study 1
Travel population reconstructed for a group holding no data
A company had been sending staff abroad for years and held no central record of who went where. We pulled the travel bookings and the expense data, built a per person, per country day count for the open years, and separated the travellers into those within an exemption, those outside it, and those whose position depended on facts that still needed establishing. The engagement produced a day count the company could stand behind, a written position for each country reached, and a short list of individuals who needed filings made for them.
Case study 2
Authority enquiry into a project team working at a customer site
A host authority asked why no payroll was registered for a team that had been visible on a customer's premises for months. We assembled the travel and contractual evidence, established which part of the presence fell within the treaty's employment article and which did not, and dealt with the authority directly. The work produced a documented response, a registration and withholding position going forward, and a settlement of the earlier periods on the basis of the days that were actually taxable rather than the authority's opening assumption.
Case study 3
Directors attending board meetings abroad treated as ordinary travellers
A group had assumed its non executive directors were business visitors like anyone else. Directors' fees are frequently dealt with under a treaty article of their own, which does not work the way the employment article does, and the place where meetings were held mattered more than anyone had realised. We reviewed the appointments, the fee arrangements and where the meetings were actually convened, and set out the position for each country involved. The engagement produced a written analysis per director, and a change to how meeting locations are recorded in the minutes.
Case study 4
Trainers delivering courses on customer sites across several countries
A company's technical trainers travelled to customer sites to deliver paid training, and the cost of their time was embedded in the customer contract. That made the question harder than a simple visit, because the work was being performed for the customer in that country. We reviewed the contracts alongside the travel record, established where the combination of presence and cost recovery created a taxable position, and advised on withholding. The work produced a country by country assessment and a revised contracting approach for training delivered outside the home country.
Case study 5
Pre travel approval introduced after an unmanaged year came to light
Once the company knew its exposure, the remaining question was how to stop it recurring. We designed a short approval step taken before any trip abroad, capturing the destination, the dates, whose work is being done and who bears the cost, before the booking is made rather than a year later. Thresholds were set per country from the applicable treaty articles rather than from a single house rule. The engagement produced the process, the country thresholds behind it, and a monthly report the tax function can act on while a year is still open.
Case study 6
One traveller whose days aggregated across two group entities
An individual was employed by one group company and spent part of each year working for a sister company in another country, with the trips booked and expensed separately by each. Each entity saw a small amount of travel; the country saw one person present for a substantial part of the year. We combined the records, tested the total against the applicable article, and established that the exemption had failed. The work produced a consolidated day record for the individual, a host country filing, and a rule for aggregating travel booked by different entities.
Case study 7
Three Countries in One File and Two Treaties That Disagree
Income sourced in one country, paid to a resident of a second, held through an entity in a third: three bilateral treaties, no three-way rule. The analysis works out which pair governs each flow, and whether the middle entity is entitled to anything at all.
Read how this one runs
Case study 8
A US Filer Married to Someone Outside the System
Electing to treat a non-resident spouse as a US filer buys joint rates and brings that spouse's worldwide income and foreign accounts into the return. The election is easy to make and hard to revoke, so both positions are modelled first.
Read how this one runs
