This article considers how UK companies should manage expatriate managers in Iraq who hold dual appointments, provide temporary cover or move between sponsoring entities. A manager may oversee several group companies or step in for a colleague elsewhere. Corporate approval of that arrangement does not settle the manager’s immigration or employment position: residence, work authorisation and authority to represent a company serve different legal purposes and should be reviewed together.
In Federal Iraq, the Foreigners Residence Law No. 76 of 2017 governs entry and residence, the Labour Law No. 37 of 2015 regulates work permits for foreign employees, and the Workers’ Retirement and Social Security Law No. 18 of 2023 may also apply. The Companies Law No. 21 of 1997 and the Notaries Public Law No. 33 of 1998 govern corporate representation. Kurdistan Region operations require separate assessment of local procedures.
Dual appointments and actual work
A corporate office differs from the activities performed under it. A director attending occasional board meetings is in a different position from a manager supervising staff, signing operational contracts and working daily at the premises, and job titles alone do not determine immigration treatment.
Where the manager serves two entities, the documents should identify the employer, the entity directing the work and the sponsor for immigration purposes. Review of employment arrangements in Iraq should consider whether the second role changes contractual duties, payroll reporting or social security obligations, since group-wide policies do not replace the need to identify local legal relationships.
Temporary cover and the permitted activity
Temporary cover can turn into a continuing assignment without anyone updating the documents. The company should compare the expected duration, location and substance of the work with the permissions held. A valid residence permit linked to one company should not be assumed to authorise work for another group entity.
The same applies when a visiting executive stays to manage an emergency. Business urgency may explain the assignment but does not create a work permit exemption. Any exception should be identified from the rules and the individual’s circumstances, not inferred from the short length of the original visit.
Changes in the sponsoring entity
Moving between group companies may require amendment, cancellation or a fresh application, depending on the permission and the authority’s requirements. The correct sequence should be established before the existing arrangement ends, as premature cancellation may leave the manager without lawful status while new documents are processed. The review should cover:
- Current residence and work documents and their expiry dates.
- The existing employer and the proposed receiving entity.
- Changes in duties, work location and reporting lines.
- Required supporting records, notifications and approvals.
The company should keep evidence of the authority’s decision rather than rely on an internal transfer letter.
Consequences of non-compliance
Working outside the conditions of a residence or work permit can lead to fines, deportation and entry bans for the individual and penalties for the sponsoring company. For senior managers, the operational impact can be severe: a manager stopped at the airport or unable to renew a permit may leave bank mandates, contracts and government files without an authorised signatory. Compliance calendars and early renewal applications reduce this risk.
Corporate authority and operational continuity
The manager may also hold powers of attorney, bank mandates or registration responsibilities that do not change automatically with the employment or immigration arrangement. Iraqi corporate authority documents should be reviewed separately, including whether an outgoing manager can still bind an entity after leaving the role, and revoked powers should be cancelled before the notary.
Temporary delegation can maintain operations if the replacement has the necessary authority and permits. Contract signatories, government correspondence and bank access should be coordinated with effective dates, and records should reflect the transition accurately without backdating. Assignment terms should state who pays relocation and application costs, without implying that cost allocation transfers statutory responsibility from the employer.
Tax and social security for dual roles
A manager paid by more than one entity, or by a UK company while working in Iraq, raises questions about personal income tax on Iraqi-source earnings and social security contributions. Each paying entity should understand its obligations, and the total remuneration should be reported consistently. Payments made from the UK do not by themselves remove Iraqi obligations, and the group should document how the arrangement has been assessed.
Group mobility policies should be adapted for Iraq accordingly. A short checklist for HR and legal teams, covering permit status, employer of record, payroll and corporate powers, can be completed whenever a manager’s role changes. This ensures that operational decisions about cover and reassignment take account of Iraqi legal requirements, rather than being treated purely as internal staffing matters.
Conclusion & how Etihad Law Firm can help
Management changes in Iraq require coordination across corporate, employment and immigration rules so that the company’s operations and the manager’s legal status stay aligned.
As Iraq immigration legal counsel for UK-based companies, Etihad Law Firm manages residence and work permit applications and transfers, reviews employment and secondment documents, and prepares and registers powers of attorney, helping UK businesses handle dual appointments and moves between entities without compliance gaps.