Employees are working abroad. Companies don't know.
Published survey data and documented enforcement actions on undisclosed cross-border remote work — the exposure Njokey exists to close. Sources cited throughout.
- Sources
- MBO · Topia · Vialto · WorkFlex · KPMG
- Covers
- Surveys, enforcement cases, forecasts
- Horizon
- Actuals to 2025 · forecasts to 2030
- Risk areas
- Tax · PE · GDPR · payroll · employment
- Note
- Informational — not legal or tax advice
The workforce has gone global — undetected
US digital nomad numbers have grown 153% since 2019, and the share of employees working cross-border keeps rising faster than the share who tell HR.
US digital nomad population
Millions of workers. Actual figures from MBO Partners State of Independence; starred years are Research & Markets projections.
Worked cross-border vs. told HR
% of surveyed employees. The disclosure gap widened from 32 points to 45 points in one year. Source: Topia surveys 2022–2023, n = 1,800+.
Companies are in the dark
HR confidence in knowing where employees work fell 14 points in a single year. Work-from-anywhere policies exist on paper — the safeguards mostly don't.
Remote employees working abroad, by consent
Share of US remote workers working abroad with vs. without formal employer consent. Source: MBO Partners, 2025.
HR confidence: "I know where my employees work"
Share of HR leaders confident they know where employees are working. Source: Topia / Vialto survey data.
Fewer than half of HR teams are now confident they know where their own workforce is.
Work-from-anywhere safeguards actually in place
% of companies with WFA schemes that implemented each safeguard. Source: WorkFlex 2024 survey.
The calendar problem: days abroad become tax liability
Most countries use day-count thresholds to determine corporate tax presence ('permanent establishment'). One employee working abroad long enough can create six-figure obligations — without the company knowing.
How many days trigger risk?
Thresholds vary by country — and are often crossed unintentionally. Sources: KPMG, Thomson Reuters, Ogletree 2026 PE guides.
| Country | PE trigger threshold | Risk |
|---|---|---|
| 🇩🇪 Germany | 183+ days / year | High |
| 🇫🇷 France | 183+ days / year | High |
| 🇬🇧 UK | 90+ days, certain roles | Critical |
| 🇦🇺 Australia | 183+ days / year | High |
| 🇮🇳 India | 60+ days, senior staff | Critical |
| 🇧🇷 Brazil | Any fixed place of business | Critical |
| 🇨🇳 China | 183+ days, or any authority | Critical |
| 🇺🇸 US states | Varies: 1 – 183 days | Medium |
Twelve months of undetected work abroad
Illustrative scenario — a UK-based employee quietly working from Spain on weekdays. Foreign work days accumulate toward the PE threshold month by month.
183-day thresholds apply in most EU countries; India and others trigger at 60 days for senior staff. Scenario is illustrative, not survey data.
This is already happening
Documented enforcement actions, fines and settlements involving cross-border work. These are confirmed, sourced incidents — not projections.
Known enforcement actions & fines
Google reached a £130M settlement with UK tax authorities over disputed profits linked to employees operating in the UK — a landmark PE case in global compliance literature.
£130,000,000Indian authorities argued Netflix created a permanent establishment through employees operating locally — a tax bill despite no formal office in India.
≈ €2,000,000Luxembourg's Labour Authority (ITM) imposed cumulative fines of €8.9M for worker-posting non-compliance in 2023 alone. Inspections nearly doubled year over year.
€8,900,000Italy activated enforcement of its remote-work legislation (April 2024), with administrative fines of €100–€500 per affected employee for non-compliant employers.
€100–€500 / employeeMisclassifying five remote employees at $80K salary over three years creates an estimated $205,000+ liability in back taxes, penalties and interest — before state-level obligations (Jackson Lewis, TaxRavens).
$205,000+ per caseWhat non-compliance actually costs
Estimated cost per incident, USD thousands. Composite of documented penalty structures — Jackson Lewis, Ogletree, TaxRavens, EU enforcement data. Indicative, not a quote.
The gap is widening, fast
Global digital nomad numbers are forecast to hit 60 million by 2030, and digital nomad visas make longer stays abroad easier every year — while tax authorities tighten enforcement.
Global digital nomad population
Millions. Actual figures to 2025 (solid), Research & Markets projections to 2030 (dashed).
Countries offering digital nomad visas
Cumulative count. Legal frameworks for long stays abroad keep multiplying — with or without employer knowledge. Sources: Lockton, Global People Strategist.
Sources & method
MBO Partners State of Independence Report (2024, 2025) · Topia Adapt Survey (2022, 2023) · Vialto Partners Mobility Agility Survey · WorkFlex 2024 Survey · Payroll.org "Getting the World Paid" 2025 · KPMG Permanent Establishment Risk Guide 2026 · Thomson Reuters Permanent Establishment Guide 2026 · Ogletree Deakins Cross-Border Work Analysis · Jackson Lewis Cross-Border Employment Series · Research & Markets Digital Nomad Services Report 2026 · Lockton Global Benefits Remote Work Legislation Tracker · Luxembourg Labour Authority (ITM) Annual Report 2023 · Italy remote work law, April 2024.
Statistics reflect the cited published surveys and enforcement records; projections and illustrative scenarios are labelled as such. This page is for information only — not legal or tax advice.
Close the gap before an auditor finds it.
Njokey gives you a verified, consent-based answer to where your workforce actually is — before day counts become tax bills.
