2026: Global Mobility at a turning point

As we move into 2026, global mobility programmes are entering a period of accelerated change. What were once technical cases; remote work, business travel, shadow payroll and social security, are now firmly on the radar of tax authorities, finance teams, and boards.

A combination of US domestic tax changes, increased Internal Revenue Service (IRS) scrutiny, and OECD-led international developments is reshaping how organisations must think about globally mobile employees. The message is clear: mobility can no longer operate in silos. Below we highlight the key developments to be aware of and what global mobility teams should be doing now.

We highlight what’s new and what global mobility teams should be doing now.

US Tax Law Changes: Why 2025–26 matters for mobile workers

The One Big Beautiful Bill Act (OBBBA), enacted in 2025, introduces several changes that may not look like ‘mobility legislation’ on the surface but have real consequences for internationally mobile employees and their employers. Key provisions include:

• The permanent extension of individual tax rates and higher State and Local Taxes (SALT) deduction limits, particularly relevant for senior, high-earning mobile employees
• New and expanded deductions, which can materially affect net pay calculations and assignment cost models
• A 1% excise tax on certain electronic remittances from the US, effective from 1 January 2026, which may impact expatriates and globally mobile individuals sending funds overseas

For global mobility teams, these changes feed directly into cost projections, tax equalisation calculations, and employee communications. What can appear minor at a legislative level can quickly become significant at scale.

The IRS is watching the gaps, not just the numbers

Alongside legislative change, the IRS has continued to sharpen its focus on international reporting and compliance risk. We are seeing increased scrutiny in areas such as:

• Incorrect residency determinations under the Substantial Presence Test
• Mismatches between payroll reporting and personal tax filings
• Incomplete reporting of worldwide income and foreign assets, including Forms 8938, 5471 and 8865

Importantly, many IRS enquiries are now being triggered by data inconsistencies, not underpaid tax. For mobile employees, this means that even where the ‘right amount’ of tax is ultimately paid, how and where income is reported matters more than ever.

Inflation adjustments: small changes, big modelling impacts

For the 2026 tax year (returns filed in 2027), inflation-related adjustments to US tax brackets and the standard deduction are already in motion. While routine, these changes can materially affect:

• Assignment cost estimates
• Gross-up calculations
• Net-to-net comparisons across jurisdictions

Mobility programmes that rely on outdated assumptions risk mispricing assignments and creating avoidable cost volatility.

The remittance tax: A new cash-flow consideration

From 1 January 2026, a 1% excise tax on certain cross-border remittance transfers adds a new layer to global mobility planning. For mobile employees and remote workers, this raises practical questions:

• How are personal cash flows structured?
• Who bears the cost, employer or employee?
• How is this reflected in tax equalisation policies?

It is a reminder that mobility planning extends beyond payroll and tax returns into real-world employee behaviour.

OECD Remote Work Guidance: From Theory to Enforcement

Perhaps the most significant shift for global mobility comes from the Organisation for Economic Co-operation and Development (OECD). The 2025 update to the OECD Model Tax Convention moves remote work and permanent establishment (PE) risk firmly from theory into practice. Tax authorities are increasingly asking: Who worked where and why?

Key implications include:

• Remote work by senior decision-makers now carries greater PE risk than volume headcount
• Historical travel and working patterns are being used as evidence
• Informal or undocumented remote arrangements are becoming harder to defend.

For global mobility teams, this reinforces the need for robust governance, accurate data and clear approval frameworks for business travellers and remote workers.

Further reading can be found here: OECD November 2025 Update: Remote Work and Permanent Establishment – Blick Rothenberg

Pillar 2 meets global mobility: The overlooked people risk

With Pillar 2 and Qualified Domestic Minimum Top-up Tax (QDMTT) now live, people costs are being pulled into group tax calculations in ways we haven’t seen before. Mobility-related costs, including shadow payroll, tax equalisation, gross-ups and social security, can directly affect effective tax rate calculations. This exposes a common disconnect:

• Tax teams focus on compliance
• Finance teams focus on modelling
• Mobility teams hold the underlying data

Bridging this gap is quickly becoming a priority. Our specialists can help you navigate the new tax landscape, manage compliance risks, and optimise costs for your mobile workforce.

—

Source: https://www.blickrothenberg.com/insights/detail/2026-global-mobility-at-a-turning-point/