Reference
GemmWork Glossary
Definitions for key terms used across GemmWork's analysis and GEMM Framework.
PE & Tax
A fixed place of business in a foreign country that subjects a company to local corporate taxation.
183-Day RuleThe OECD threshold after which a worker's presence in a country triggers potential PE and tax residency obligations.
CON-Strategic (GEMM-05)The highest-risk GEMM mode: a fully embedded independent contractor with strategic decision-making authority.
Employment Structures
A third-party company that serves as the legal employer for workers in foreign countries, handling payroll, taxes, and compliance.
Worker Misclassification RiskThe legal risk that a contractor relationship is reclassified as employment, triggering retroactive tax and benefit obligations.
EOR Breakeven PointThe headcount at which establishing a local entity becomes cheaper than paying ongoing EOR fees — typically 15–25 employees in the same country.
GEMM Framework
A GemmWork scoring variable measuring how difficult it is to terminate employment or exit an EOR arrangement in a given country.
Hotel California (EOR)The phenomenon where exiting an EOR arrangement triggers mandatory severance and statutory costs that can reach $15,000–$45,000 per employee.