Abstract
There are many businesses operating worldwide because of globalisation. As a result,
there is a global growth of expatriates and a transfer of human capital between various
tax jurisdictions. Understanding the tax regimes of several countries as they relate to
expatriate taxation is necessary for this mobility. Although every country was different,
there are certain commonalities, such as the ability to share taxation principles, taxing
residents on their worldwide income, and the exemption on foreign employment income.
This enables comparisons between countries with comparable tax structures, such as
those in SA, Ghana, the United Kingdom, and Australia, which all use residence-based
taxation.
The world changed quite drastically in 2020. The World Health Organization declared
Covid-19 a pandemic, which affected the entire world. Governments were driven by the
pandemic to enact unheard-of measures, like limiting domestic and foreign travel. Many
expatriates were stranded in countries other than their country of residence or the country
where they were assigned to work because of lockdown and international Covid-19 travel
restrictions. With an emphasis on the above countries using a resident-based taxation,
this study focuses on the effects that Covid-19 had on the expatriate taxation. This study
also focuses on how the processes of the temporary amendments made to the tax laws
to remedy the abrupt disruption caused by Covid-19 affected these expatriates and if the
processes and the changes upheld the principles of distributive, procedural, and
individual fairness.
iv
This study used primary and secondary data and a qualitative research approach.
Amendments made to provisions regulating foreign employment income were reviewed
and compared between the four selected countries.
This study's conclusion is that the processes followed, and the changes made, to address
the disruption brought about by Covid-19 made the implementation of the tax exemption
on foreign employment income fairer and more practical.
Keywords:. Australia, Covid-19, distributive fairness, expatriate taxation, foreign employment
income, Ghana, global mobility, individual fairness, procedural fairness, residence-based tax
systems, South Africa, tax exemption, The United Kingdom.