FlagSageCompare countries: how each decides tax residence
Tax basis, tax year, main day figure and the kinds of tests each country uses, side by side.
Short answer
Countries use different tests, periods and counting methods. A day figure in this table is one test among several for that country. Open each country page for every test and its source.
| Country | Tax basis | Tax year | Main day figure | Kinds of tests | Taxes citizens abroad |
|---|---|---|---|---|---|
| 🇦🇷 Argentina | Residence-based | 1 January to 31 December | No day figure recorded | Citizenship, Registration, domicile or status, Ties test | No |
| 🇦🇺 Australia | Residence-based | Income year (1 July to 30 June) | 183 days, tax year | Day count, Registration, domicile or status, Ties test | No |
| 🇧🇷 Brazil | Residence-based | Calendar year (ano-calendário) | 184 days, any 12 months | Day count, Registration, domicile or status | No |
| 🇧🇬 Bulgaria | Residence-based | Calendar year (1 January to 31 December) | 183 days, any 12 months | Day count, Registration, domicile or status, Ties test | No |
| 🇨🇦 Canada | Residence-based | Calendar year | 183 days, calendar year | Day count, Ties test | No |
| 🇨🇱 Chile | Residence-based | Calendar year (año calendario: the twelve months ending 31 December) | 183 days, any 12 months | Day count, Registration, domicile or status, Ties test | No |
| 🇨🇴 Colombia | Residence-based | Taxable year (año o periodo gravable); confirm the period with DIAN | 183 days, any 12 months | Day count, Ties test | No |
| 🇨🇷 Costa Rica | Mainly territorial | 1 January to 31 December | 183 days, any 12 months | Day count, Registration, domicile or status | No |
| 🇭🇷 Croatia | Residence-based | Calendar year (1 January to 31 December) | 183 days, several years | Day count, Ties test | No |
| 🇨🇾 Cyprus | Residence-based | Calendar year (1 January to 31 December) | 183 days, tax year | Day count, Ties test | No |
| 🇨🇿 Czechia | Residence-based | Calendar year (1 January to 31 December) | 183 days, calendar year | Day count, Ties test | No |
| 🇪🇪 Estonia | Residence-based | Calendar year (1 January to 31 December) | 183 days, any 12 months | Day count, Ties test | No |
| 🇫🇷 France | Residence-based | 1 January to 31 December | No day figure recorded | Ties test | No |
| 🇬🇪 Georgia | Mainly territorial | Calendar year (1 January to 31 December) | 183 days, any 12 months | Citizenship, Day count, Registration, domicile or status | No |
| 🇩🇪 Germany | Residence-based | 1 January to 31 December | No day figure recorded | Citizenship, Day count, Ties test | No |
| 🇬🇷 Greece | Residence-based | Calendar year (1 January to 31 December) | 183 days, see source | Citizenship, Day count, Ties test | No |
| 🇭🇺 Hungary | Residence-based | Calendar year (1 January to 31 December) | 183 days, calendar year | Citizenship, Day count, Registration, domicile or status, Ties test | No |
| 🇮🇳 India | Residence-based | 1 April to 31 March | 182 days, tax year | Citizenship, Day count | No |
| 🇮🇪 Ireland | Residence, remittance basis for some | 1 January to 31 December | 183 days, tax year | Day count, Registration, domicile or status | No |
| 🇮🇱 Israel | Residence-based | Calendar year (1 January to 31 December) | 183 days, tax year | Presumption, Ties test | No |
| 🇮🇹 Italy | Residence-based | 1 January to 31 December | 183 days, calendar year | Citizenship, Day count, Presumption, Ties test | No |
| 🇯🇵 Japan | Residence, remittance basis for some | Calendar year (1 January to 31 December) | No day figure recorded | Day count, Presumption, Ties test | No |
| 🇲🇾 Malaysia | Mainly territorial | Calendar year basis year for each year of assessment | 182 days, calendar year | Day count, Presumption | No |
| 🇲🇹 Malta | Residence, remittance basis for some | 1 January to 31 December (basis year) | No day figure recorded | Day count, Registration, domicile or status, Ties test | No |
| 🇲🇽 Mexico | Residence-based | Calendar year (año de calendario) | No day figure recorded | Ties test | No |
| 🇳🇱 Netherlands | Residence-based | 1 January to 31 December | No day figure recorded | Citizenship, Presumption, Ties test | No |
| 🇳🇿 New Zealand | Residence-based | 1 April to 31 March | 183 days, any 12 months | Day count, Ties test | No |
| 🇵🇦 Panama | Mainly territorial | Check current DGI guidance | 183 days, any 12 months | Day count, Ties test | No |
| 🇵🇱 Poland | Residence-based | Calendar year (1 January to 31 December) | 183 days, tax year | Day count, Ties test | No |
| 🇵🇹 Portugal | Residence-based | 1 January to 31 December | 183 days, any 12 months | Day count, Ties test | No |
| 🇸🇬 Singapore | Mainly territorial | Calendar year of income, assessed in the following Year of Assessment (preceding year basis) | 183 days, calendar year | Day count, Presumption, Ties test | No |
| 🇿🇦 South Africa | Residence-based | Year of assessment from 1 March to the last day of February | 915 days, several years | Day count, Ties test | No |
| 🇪🇸 Spain | Residence-based | 1 January to 31 December | 183 days, calendar year | Citizenship, Day count, Presumption, Ties test | No |
| 🇨🇭 Switzerland | Residence-based | 1 January to 31 December | 30 days, see source | Day count, Ties test | No |
| 🇹🇭 Thailand | Residence, remittance basis for some | Calendar year (1 January to 31 December) | 180 days, calendar year | Day count | No |
| 🇹🇷 Türkiye | Residence-based | Calendar year (1 January to 31 December) | No day figure recorded | Day count, Presumption, Ties test | No |
| 🇦🇪 United Arab Emirates | Residence-based | Residency tests use any relevant 12 consecutive months; Corporate Tax on a natural person's Business turnover uses the Gregorian calendar year | 183 days, any 12 months | Day count, Ties test | No |
| 🇬🇧 United Kingdom | Residence-based | 6 April to 5 April | 183 days, tax year | Day count, Ties test | No |
| 🇺🇸 United States | Citizenship and residence | Calendar year (January 1 to December 31) | 183 days, several years | Citizenship, Day count, Registration, domicile or status, Ties test | Yes |
| 🇺🇾 Uruguay | Mainly territorial | Calendar year (the IRPF taxable event occurs on 31 December) | 183 days, calendar year | Day count, Presumption, Ties test | No |
The main day figure is the first verified figure in the country record. Some countries have several. "No day figure recorded" means we did not verify one, not that the country has none.
- Countries covered
- 40 countries
- Sources
- Each country page lists its sources
- Tax year
- Current rules as checked
- Review
- Not professionally reviewed
Sources checked November 8, 2026