Anyone come across EMBO (or other equalisations)?

Multi national tax equalisation scheme

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Has anyone come across EMBO, or other similar tax equalisation schemes? Schlumbeger deduct a "measure" of tax from all employees posted overseas, regardless of (and sometimes in addition to) local tax. There is no final reconciliation at the end of the year. The employee suffers the same rate at source wherever they are.  The company's rationale is that those working in low tax regimes are helping out their colleagues posted to higher tax regimes.  The inspector and I are disagreeing on the deductibility as a foreign tax credit.  Any thoughts would be appreciated. 

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