OECD: Public consultation on tax issues relevant to global mobility of individuals
Consultation closes December 22, 2025.
The Organisation for Economic Co-operation and Development (OECD) on November 26, 2025, launched a public consultation on tax and regulatory challenges relevant to the global mobility of individuals.
The consultation document outlines some of the initial tax concerns linked to global mobility that have been identified by the Inclusive Framework on BEPS as possible areas for further consideration, including:
- Individual (personal) income tax: Domestic residency tests, treaty taxing right allocation, compliance and administrative challenges for both individuals and employers, dispute resolution, and interactions between tax rules and other aspects of domestic law (e.g., social security, pension regulations, labor law, or migration law)
- Corporate income tax: Issues relating to permanent establishments (PEs), residence determination, and transfer pricing and profit attribution between countries that may arise from globally mobile employees
The consultation document notes that those initial tax concerns have been outlined for illustration purposes and are meant to assist stakeholders to provide feedback on how tax rules could better facilitate opportunities arising from global mobility, or to highlight areas where uncertainty exists with respect to current rules.
The consultation closes December 22, 2025, and will be followed by a public hearing on January 20, 2026.
Read a December 2025 report prepared by KPMG’s EU Tax Centre