Companies that outsource staff recruit employees and assign them to work at client locations, managing their salaries, benefits, and performance. These manpower services are subject to tax based on the place of supply principles. Additionally, some companies assist in obtaining visas for employees of other companies, handling visa processing and related services, known as visa facilitation services. The hiring company is responsible for employee obligations and manages the employees. This arrangement is tax-free between corporate group members, clarified by the Federal Tax Authority (FTA) in Public Clarification No. VATP038, exempting such services within the same corporate group. However, strict conditions apply, including that the facilitator must not provide manpower services and must transfer all employee obligations to the group member where the employee is assigned. Compliance with these conditions is crucial to avoid taxation on manpower supply.
Text: Lara Palmer
16.06.2024
Understanding the nuances of manpower and visa facilitation services within corporate groups