Secondment and TP Risk When: Employees Trigger Tax Trouble

 “Secondments might look like simple HR moves — but tax authorities see more.”

If a foreign employee works in India, is it really a secondment? Or is it a cross-border service?

The answer could trigger:

  • Arm’s length charges
  • PE exposure
  • Transfer pricing compliance

In TP, even people can create risk. Here’s what you need to know.

As businesses globalize, sending employees on secondment to group companies in other countries has become routine. But for Transfer Pricing (TP) professionals, this simple HR move can quickly turn into a tax compliance puzzle.

The key question:

Is the secondee truly an employee, or is this actually a cross-border service? Let’s unpack this grey area.


What is a Secondment?

In a secondment arrangement, an employee of one entity (say, the foreign parent) is temporarily assigned to another entity (like an Indian subsidiary). The secondee works under the host company’s direction but remains on the home company’s payroll.

Want to know more check the link- https://uja.in/blog/transfer-pricing/secondment-and-tp-risk-when-employees-trigger-tax-trouble/

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