Christian Glagla, Head of Client HR Services and Angela Bartl, MD - Strategy and Business Development both from TMF Group Germany, examine the different ways employee leave is applied in countries across Europe and the Middle East.
Managing multi-country payroll can be made more complex by specific employee leave entitlements that must be adhered to. In some European nations public holidays must be paid, and can range from 14 days in Malta to 12 in Russia and just two in Norway. Germany has certain official paid public holidays, and different German states then have their own set paid holidays, so company payroll functions must account for regional variations within the country. In the Netherlands, public holidays that fall on a weekend are not transferred to the next working day.
Keeping on top of the different government-sanctioned days can be difficult, but how else can employee leave entitlements differ across EMEA?
Norwegian employees are not entitled to holiday pay during the first year of their employment, but they are still entitled to leave. However if they have worked with another employer prior to their current job, they will receive holiday pay from the previous employer. The holiday pay (called “feriepenger”) is based on the income of the previous year and can include extra work-related remuneration such as bonuses. Technically, this is supposed to be paid at the time the leave is taken, but to ease the administrative burden on payroll, most companies will process it in June and replace the salary for that month with the holiday pay.
Employers contribute between 10.2% and 12% of the employee’s monthly salary to holiday pay, and the standard leave duration is five weeks with a minimum duration of 21 days. However, where an employee is over 60 years of age the entitlement may be extended for one additional week.
French citizens are entitled to 30 days of annual leave, but employees who wish to work for more than 35 hours a week receive up to 22 days extra, which is called the RTT (Reduction du Temps). As a result, companies have to closely track any extra hours logged by employees and factor them into their payroll processing. Any further hours after the RTT period are usually compensated with remuneration. Employees in France that take a portion of their holiday outside of the traditional summer leave period of August can also be entitled to bonus leave days.
If an employee in Russia is completing distance education through a qualified university for a bachelor or master’s degree, they are entitled to additional paid study leave during exam sittings. The employer is obliged to provide paid leave of up to 30 days per academic year in the first and second year, and up to 50 days in further years. Paid leave for final state attestation with a duration of up to four months is stipulated by labour legislation. Alongside this, the studying employee is entitled to at least 28 days’ annual leave.
In Germany, an employee with a five-day working week (full time, average working hours per week: 40 hours) is entitled to 20 days annual leave in addition to the aforementioned public holidays that may vary from state to state. 12 working days off in a row should in general be granted for best recreational effect, and where an employee falls ill whilst on annual leave, a doctor's certificate will mitigate the loss of vacation days.
Employers are not permitted to reduce the mandatory number of annual leave days, except in a case of pro rata reduction and under certain conditions where the employee is engaged on a part time basis. Any adjustment for the benefit of the employee is allowed, and in many companies routine, or agreed in certain public contracts (“Tarifverträge”). A termination of employment in the first half of a year (until the end of June) will result in a pro-rata calculation of annual leave. Most German states (except for Bavaria and Saxony) also offer employees the possibility to apply for educational leave however the procedure and duration of that leave may vary.
United Arab Emirates
Companies with staff in the United Arab Emirates must provide them with at least 30 annual leave days after more than one year of service. If the employee leaves the business before the 12 month mark, they are entitled to two days’ leave for every month. In the private sector though, no leave is accrued during the first six months of employment.
The leave entitlement in the public sector is also 30 days, while civil servants must receive a minimum of 22 annual leave days. The UAE Labour Law allows Muslim employees in the private sector unpaid leave amounting to 30 days which can be taken once during their period of employment. This is to be used to perform the Hajj (the annual Islamic pilgrimage to Mecca). Hajj leave amounts to 15 days for public sector employees; it is fully paid, and can be taken on two occasions during their career, as long as the period between the two instances is at least 10 years.
National holidays are not counted as part of annual leave in the UAE, and the length of these holidays is determined by the Ministry of Labour. Public holidays that fall on a weekend are not made up for during the working week, and staff that are required to work on these days generally receive a lieu day or overtime payment.
Partner with the local experts
A third party HR and Payroll provider such as TMF Group has payroll experts in more than 80 countries who understand the rules surrounding local leave allowances. They can calculate your employee entitlements and make sure they’re processed correctly, leaving you to focus on doing business.
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