Cross-border posting within a corporate structure
A German parent company assigns a senior manager to a Dutch subsidiary. The employment contract remains formally with the German entity, while the manager actually performs all of his work in the Netherlands. The labor costs are charged to the Dutch company using a cost-plus system.
Listen
Nassau reviewed the tax positions of both the employee and the relevant group companies. Among other things, the following aspects were assessed:
Taxation of Salaries in the Netherlands and Germany
application of tax treaties
Social Security in Cross-Border Employment
potential permanent establishment for the German parent company
Analysis
Based on this, the structure of the secondment was reassessed. This involved examining the proper allocation of salary, the role of the Dutch company as the economic employer, and the manager’s position within the international group structure.
Hands-on implementation
Nassau oversaw the implementation of the structure, including payroll obligations, tax filings, and social security registrations. This ensured that both the organization and the employee complied with the relevant international obligations.
