Skip to main content

KPMG article: Potential permanent establishment, transfer pricing challenges associated with mobile workers

Survey examines tax administration approaches to remote workers, geographically dispersed senior management, and related exit tax risks.

Download PDF
September 24, 2026

A KPMG survey of transfer pricing professionals in 22 jurisdictions examines how tax administrations are addressing permanent establishment (PE) and transfer pricing issues arising from remote workers and geographically dispersed senior management. The survey highlights differences among jurisdictions in PE assertions, challenges to cost-plus remuneration for entities employing senior executives, and potential exit tax consequences when key decision-makers relocate.

Read a September 2026 article* prepared by KPMG tax professionals.

*Reproduced with permission from Tax Management International Journal,9/24/2026. Copyright @ 2026 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.
All fields with an asterisk (*) are required.

Job seekers

Visit our careers section or search our jobs database.

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Office locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Headline