Deloitte's 2026 Global Tax Policy Survey finds OECD Safe Harbour reforms and simplified cross-border rules may benefit internationally mobile Canadian professionals
A series of significant reforms to international tax rules could reduce the tax exposure of Canadians living and working overseas, even as the broader global tax environment becomes more complex and compliance-heavy.
The findings come from Deloitte's 2026 Global Tax Policy Survey which gathered the views of 1,010 senior tax and finance leaders from organisations with $100 million or more in annual revenue across 28 jurisdictions between January and March of 2026.
The survey examines six major policy themes: transparency and reporting, digitalization of tax, taxing work and wealth, international tax reform, sustainability, and trade policy and tariffs.
Permanent establishment risk is shrinking, albeit slowly
One of the most persistent cross-border tax challenges for Canadian professionals working internationally is the risk of inadvertently triggering what tax law calls a permanent establishment, the legal threshold at which a worker's presence in a foreign country creates a taxable corporate footprint for their employer.
For Canadians on short-term overseas assignments or working remotely from abroad, crossing that threshold can produce unexpected tax obligations in jurisdictions where neither the individual nor their employer intended to establish a taxable presence.
The Deloitte survey found that approximately 39 per cent of respondents expect recent changes to the Organisation for Economic Co-operation and Development's (OECD) Model Tax Convention and Commentary — the international framework governing how taxing rights are allocated between countries — to reduce the number of such inadvertent small permanent establishments.
The report notes that these situations are disproportionately burdensome: small amounts of cross-border work, producing modest amounts of tax revenue, can nonetheless generate significant compliance and administrative costs for businesses with staff operating in multiple jurisdictions.
Looking forward, the survey found that 27 per cent of respondents identified a Safe Harbour threshold as the most useful next step from the OECD — one that would permit workers to spend a set number of days in a foreign jurisdiction, or undertake certain categories of activity, without triggering a permanent establishment.
A further 22 per cent called for clearer rules to prevent small or technical permanent establishments with limited profits from being created, while 19 per cent expressed support for an employer waiver programme.
Fewer inadvertent permanent establishments would mean fewer unexpected tax liabilities in foreign jurisdictions, and a materially less complicated compliance landscape for internationally mobile clients.
The Pillar Two Safe Harbours and what they mean for Canadians
The Deloitte survey's chapter on international tax reform identifies the negotiation of the Side-by-Side package as the most significant global tax development of the past year.
Designed to support the global implementation of the OECD's Pillar Two regime — the framework establishing a global minimum corporate tax rate of 15 per cent — the package introduced four new Safe Harbours, according to the report: the Simplified Effective Tax Rate Safe Harbour, the Substance-Based Tax Incentives Safe Harbour, the Ultimate Parent Entity Safe Harbour, and the Side-by-Side Safe Harbour. The existing Transitional Country-by-Country Reporting Safe Harbour was extended for one year.
Canada has been an active participant in Pillar Two implementation. The Canada Revenue Agency (CRA) has been developing its domestic minimum top-up tax framework in alignment with the OECD's global rules, making the survey's findings on Safe Harbour adoption particularly relevant for Canadian businesses and their advisors.
The Deloitte report found that around 80 per cent of respondents expected their organisations to be affected by the new Safe Harbours — a figure the survey describes as indicating the benefits of the regime are likely to be widespread.
Some 58 per cent of respondents said the new provisions would increase complexity in some areas but nonetheless viewed them as a helpful development overall, while 41 per cent identified further Pillar Two simplification as their top priority for international co-ordination.
Foreign jurisdictions are offering more generous talent incentives
The survey also found that governments worldwide are intensifying their use of tax incentives to attract internationally mobile professionals.
According to the Deloitte report, 57 per cent of respondents said their jurisdiction is increasing the value of special tax regimes and incentives to attract foreign talent. Only 20 per cent said incentive values are declining, and a further 20 per cent reported no change.
The survey also found that 57 per cent of respondents believed existing incentives would remain valuable to their business because they are taken into account in Pillar Two calculations, while 38 per cent expected new incentives would be introduced. Piet Verswijver, CHRO Platform Leader at Deloitte Belgium, observed in the report that businesses deploying cross-border personnel would welcome a simplification of international tax rules — and, ideally, their alignment with social security initiatives — to support both talent attraction and cost clarity.
Compliance demands are rising across the board
Despite the pockets of reform documented in the Deloitte survey, the report's overarching conclusion is clear: tax complexity is increasing, not decreasing.
Transparency and reporting requirements ranked as the top business impact theme for the third consecutive year, cited by 65 per cent of respondents. The single most significant operational driver, according to the report, was the increase in compliance, administrative, and reporting requirements, with sourcing and verifying data identified as the leading execution challenge across all themes.
Amanda Tickel, Deloitte's Global Tax and Trade Policy Leader, said in the report that the central challenge going forward is balancing the benefits of policy against the costs and burdens of compliance.
Clients with cross-border assets, foreign employment income, or international business interests are already navigating obligations under the CRA's T1135 Foreign Income Verification Statement — required for Canadians holding foreign property exceeding $100,000 at any point during the tax year — as well as treaty-based disclosures and foreign reporting requirements. The global escalation of reporting obligations documented in the Deloitte survey compounds that burden for any client with European or multinational exposure.
The survey also pointed to longer-term change in how tax authorities will operate. The OECD's Tax Administration 3.0 concept — a framework for fully digitalised, near-real-time tax compliance — is gaining traction globally, with 60 per cent of respondents telling Deloitte they are already seeing movement toward this model in their jurisdiction.
The report found that 68 per cent of respondents expect artificial intelligence to produce faster and more efficient tax audit processes, but 45 per cent also flagged that AI-driven audit findings may become harder to understand and challenge — a development that could affect how Canadian clients with foreign tax obligations navigate cross-border audits in future.
