Purpose of the hire
Product, support, research, or sales each create different commercial and tax questions. Name the purpose in writing.
An employer of record can employ the first local team while you learn whether the market deserves a subsidiary. Keep employment, commercial activity, and tax presence as separate questions.
Tax presence is a separate analysis. Hiring through an EOR does not, by itself, close a permanent-establishment question. See EOR and permanent establishment.
Teams get stuck when the first hire is treated as a permanent operating model. Write the review date at the same time as the start date.
Product, support, research, or sales each create different commercial and tax questions. Name the purpose in writing.
A dated plan with a low and high headcount is more useful than a single βwe will seeβ statement.
Examples: local contracting, a licence, banking, a lease, or a documented cost crossover. There is no universal headcount rule.
Preserve compensation, service history, and accrued balances where local law or the agreed transfer requires it. Sequence payroll registrations before the employing party changes.
We will separate employment administration from the commercial and tax questions that still need advisers.
Last reviewed: 29 September 2026. General operational information only; not legal or tax advice.