Earlier this week, I attended the OECD public consultation meeting on the global mobility of individuals in Paris. The session brought together policymakers, tax authorities, social security experts and practitioners from across the world to discuss how existing frameworks are coping with the reality of modern work.
What quickly became clear is that this conversation has moved on.
This is no longer about isolated tax questions or niche mobility scenarios. It is about how interconnected tax, social security, payroll and immigration rules are struggling to reflect how people actually live and work today.
For organisations managing cross border remote work, this discussion matters. A lot.
Why the OECD Consultation Matters
Global mobility rules were designed for a very different world. One where work was tied to offices, assignments were formal and temporary, and location was largely predictable.
That world as we know it no longer exists.
Remote and hybrid work are now embedded in how companies hire, retain and deploy talent. Employees are choosing where to live based on lifestyle, family and cost of living, while employers are approving Work From Anywhere arrangements at scale.
The OECD consultation was an explicit recognition that existing tax concepts are struggling to keep up with this reality, and that the gap between tax law and how work is actually performed is widening.
Importantly, there was a deliberate shift at the OECD toward broader topics. Rather than focusing narrowly on income tax, the discussion spanned tax, social security, payroll mechanics, equity compensation, immigration and digital nomad regimes. There was strong agreement that these issues are inherently interconnected and cannot be addressed in isolation.
A Clear Shift in Tone
One of the most encouraging signals from the consultation was the tone of the discussion.
Rather than questioning whether cross border remote work should exist, the focus was firmly on how to manage it sensibly.
There was broad acknowledgement across the room that:
- Cross border remote work is no longer an edge case.
- Blanket bans and overly conservative interpretations are not sustainable.
- Employers need clearer, more practical guardrails.
There was also an unambiguous recognition that current compliance rules are often too complex. That complexity is no longer seen as a necessary trade off for compliance. Instead, it is increasingly viewed as something that creates confusion, delays decisions and increases risk.
This represents a meaningful shift from the uncertainty that has dominated the last few years.
Key Themes Emerging From the Discussion
While this was a consultation rather than a policy announcement, several themes stood out clearly.
Greater Focus on Practical Risk, Not Hypotheticals
There was strong recognition that not every instance of remote work creates tax or Permanent Establishment risk. The discussion repeatedly centred on substance, duration and genuine business activity, rather than technical edge cases.
This mirrors how many organisations are already trying to manage Work From Anywhere in practice, using thresholds, approval workflows and role based risk assessments.
A particularly strong theme was the frustration with day count driven triggers, especially for payroll tax.
Melissa Dejong from the OECD Secretariat went into detail on how payroll tax day triggers are, in many cases, a major source of friction for work from anywhere cases. These triggers can apply mechanically, even where underlying risk is low.
That issue was reinforced by Dr Sandra Kammer from Maastricht University, who highlighted how day triggers in double tax agreements often fail to align with social security agreements and frameworks. Employers are left navigating parallel systems that do not speak to each other.
Professor Pasquale Pistone from IBFD added that some countries apply practical day count thresholds that simply do not reflect how work is actually performed, leading to outcomes that feel arbitrary rather than risk based.
Permanent Establishment Remains a Core Concern
Permanent Establishment risk continues to sit at the centre of the Work From Anywhere conversation.
What was notable was the shift away from fear driven assumptions. The discussion increasingly focused on substance over presence, with particular emphasis on authority to conclude contracts, revenue generating activity and the nature of long term presence.
James Macpherson from Deloitte spoke about the importance of greater harmonisation across OECD and non OECD countries, noting that inconsistent application of Permanent Establishment concepts continues to undermine employer confidence.
While recent OECD commentary has helped clarify that home working alone rarely creates a Permanent Establishment, the consultation made clear that further guidance is still needed to give employers confidence in real world decision making.
Tax Is Only One Part of the Puzzle
Another consistent theme was the need to look well beyond income tax alone.
Social security emerged as a major topic throughout the day. Silvia Kersmakers from the European Commission spoke about the EU teleworking framework for social security, and highlighted a key disconnect. International remote work is not well reflected in how these rules are actually being used in practice.
There was repeated discussion around whether social security should follow where work is performed or where tax rules apply. Under the current system, these assessments can produce different and sometimes conflicting outcomes.
Equity compensation was also raised as a growing challenge. On this, Carolyn Chambers from KPMG spoke about share options and other equity instruments, and how they introduce additional complexity for internationally remote employees, often without clear guidance.
Digital Nomads and New Mobility Models
New mobility models featured prominently in the discussion.
Nickson Omondi from the Kenya Revenue Authority spoke about how Kenya’s digital nomad visa fits into the country’s broader strategy to attract international talent.
Tami Moennig from TaxMoon Consulting shared practical insights into the realities of challenger digital nomad visas and how they operate in practice.
Rosa Freitas Soares from Nova Tax Labs highlighted how expatriate regimes and digital nomad frameworks can create disconnects between social security and tax regimes, adding further layers of complexity for employers.
I also spoke during the session about the challenges global mobility and HR leaders face when approving Work From Anywhere requests, particularly where tax rules, immigration frameworks and internal policies are pulling in different directions.
Hire From Anywhere models were raised also as an area that deserves greater focus in future OECD deliberations, especially as they become more central to workforce strategy.
What This Means for Work From Anywhere Programmes
For organisations running or considering Work From Anywhere programmes, the direction of travel is encouraging, but it does not remove the need for structure.
The consultation reinforced several realities that employers are already feeling:
- Informal or unmanaged remote work is increasingly risky.
- Clear policies, approvals and tracking matter more than ever.
- Data and documentation will be critical as tax authorities modernise enforcement.
In short, flexibility still needs governance. Speaking to you global tax advisors on the implications of these OECD changes will be a good starting point.
What Happens Next
The OECD will now review the feedback received through the written consultation and the Paris meeting. This will inform future work streams, potential guidance updates and longer term policy direction.
Change will not happen overnight, but this process is a meaningful step toward greater clarity, especially if the momentum continues to evolve towards clarifying payroll tax and social security aspects in particular.
To access our original blog post on the OECD guidance, see here and to see our commentary submission to the OECD, see here.
Final Thoughts
The OECD consultation on global mobility is a clear signal that international tax policy is starting to catch up with how people actually work.
While uncertainty remains, the shift toward pragmatic discussion, real world scenarios, simplification and better alignment between tax and social security is a positive sign.
For employers, the message is not to wait for perfect clarity. It is to build sensible, defensible approaches to Work From Anywhere now.
The future of work is already here. The frameworks are just beginning to follow.
John is Co-founder of Work From Anywhere, a platform to help companies execute a work from anywhere strategy. John is a Chartered Accountant who speaks 6 languages and was previously the senior finance leader of a €4 billion division of FTSE-listed CRH Plc. John and his family are passionate about travelling and his eldest daughter, Rosa, while only 5 years old has already travelled to 25 different countries.
