Which countries bank and public holidays do I observe if I work remotely in one country for a company in another country and where both countries do not have identical holidays? Do I observe the holidays for the country I live in or the country the company is based in?
Only your reporting manager/HR can answer this
Would likely differ on a case-by-case basis
You should consider consulting your reporting manager/boss on this. Depending on the work culture and your roles/responsibilities, HR personnel may need to be consulted/involved in the decision making too.
By leave, a general understanding is that you would be taking a day (possibly paid) off. The number of leaves you'd take would also need to be in line with the total allowed number of days of leave in a given period (month/year) as per the norms defined by the company for your role.
The exact answer would also vary depending on the leave type. For example, if it's a festival/national holiday in the company's country of operations, it would be a day off, and you'd not be expected to work. But it it's a festival/holiday in your country of work/residence, you'd have to request a leave explicitly (if needed).
A general advise when confronted with such a situation is to discuss the same with your manager well ahead of time, so the necessary action could be planned appropriately.
It happened to me once. I asked the company at home and the guys I worked with for four weeks in the foreign country. We decided that what makes most sense is working the same days as the people you are currently working with (I wouldn’t have been able to work in an otherwise empty office anyway), and your amount of available holiday is calculated based on the rules at home. Whether that’s legal or not, I have no idea, but everyone involved thought it was reasonable so that’s what we did.
If you are forced to take a holiday you didn’t want to take, you need to discuss this with your manager or HR at home.
This is something which has no clear answer but needs to be clear from the start, so if you want to settle this right, you do this before you start working for the company in your contract negotations.
In these negotiations you can see what the company expects from you and at which days they expect you to work and at which days they don't expect you to work.
You on the other hand, you can tell them your requirements: what salary you want, and what holidays you really can't miss. After negotiating, you and the company reach a deal and that's when you know which days to work and which days you are free.
Don't leave these things implied.
The correct way is you take your leave based on the norm there = for example in the UK Scotland and Northern Ireland have different public holidays.
All the answers don't seem to realise that if you working in country A you have to follow that countries rules - we do this at my place with teams working in the UK, Russia and Ukraine