{ "name": "FlagSage rule set", "version": "2026-11-08.59a49c4d", "built": "2026-11-08", "license": "Free to read and quote with a link to the source page.", "notice": "Educational research drafted from official sources. Not tax or legal advice. No rule has been professionally reviewed.", "countries": [ { "id": "ae", "name": "United Arab Emirates", "slug": "united-arab-emirates", "region": "Middle East", "flag": "🇦🇪", "tax_year": "Residency tests use any relevant 12 consecutive months; Corporate Tax on a natural person's Business turnover uses the Gregorian calendar year", "tax_basis": "residence", "summary": "Since 1 March 2023, Cabinet Decision No. 85 of 2022 sets three ways for an individual to be a UAE tax resident: 183 days of presence in 12 consecutive months, 90 days plus a status and a home or work link, or a usual place of residence and centre of interests in the UAE. The FTA notes that being tax resident does not by itself mean a person is subject to Corporate Tax.", "residence_rules": [ { "id": "AE-RES-01", "title": "183-day physical presence test", "kind": "day-count", "text": "A natural person is a UAE tax resident if physically present in the UAE for 183 days or more within the relevant 12 consecutive months. Any day or part of a day of presence counts, and the days need not be consecutive. Days caused by exceptional circumstances beyond the person's control may be disregarded by the Authority.", "threshold_days": 183, "window": "rolling-12-months", "day_method": "any-part", "source_title": "Cabinet Decision No. 85 of 2022 on Determination of Tax Residency (unofficial translation), Article 4(2)", "source_url": "https://tax.gov.ae/Datafolder/Files/Legislation/Corporate%20Tax/Cabinet%20Decision%2085%20of%202022%20-%20For%20publishing.pdf", "source_type": "primary-law", "effective": "1 March 2023", "checked": "2026-11-08" }, { "id": "AE-RES-02", "title": "90-day test with status and link", "kind": "day-count", "text": "A natural person present for 90 days or more within the relevant 12 consecutive months is also resident if he is a UAE national, holds a valid UAE Residence Permit or is a national of a GCC member state, and either has a Permanent Place of Residence in the UAE or carries on employment or Business there. A permanent place of residence can be rented and must be continuously available.", "threshold_days": 90, "window": "rolling-12-months", "day_method": "any-part", "source_title": "Cabinet Decision No. 85 of 2022, Article 4(3); Ministerial Decision No. 27 of 2023, Articles 3 and 5", "source_url": "https://mof.gov.ae/wp-content/uploads/2023/03/Ministerial-Decision-27-of-2023-of-Tax-Residency.pdf", "source_type": "primary-law", "effective": "1 March 2023", "checked": "2026-11-08" }, { "id": "AE-RES-03", "title": "Usual place of residence and centre of interests", "kind": "ties", "text": "A natural person is resident if the usual or primary place of residence and the centre of financial and personal interests are in the UAE. Ministerial Decision No. 27 of 2023 describes the usual residence as where the person habitually spends most time as part of a settled routine, and the centre of interests by reference to occupation, family and social relations, place of business and where property is administered.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Ministerial Decision No. 27 of 2023 on Implementation of Certain Provisions of Cabinet Decision No. 85 of 2022, Article 2", "source_url": "https://mof.gov.ae/wp-content/uploads/2023/03/Ministerial-Decision-27-of-2023-of-Tax-Residency.pdf", "source_type": "primary-law", "effective": "1 March 2023", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": null, "reporting": [ { "title": "Tax Residency Certificate", "text": "A person who meets Article 3 or 4 of Cabinet Decision No. 85 of 2022 may apply to the Federal Tax Authority for a Tax Residency Certificate. Where a tax treaty sets its own residency conditions, the treaty conditions apply for that treaty.", "source_url": "https://tax.gov.ae/Datafolder/Files/Legislation/Corporate%20Tax/Cabinet%20Decision%2085%20of%202022%20-%20For%20publishing.pdf" }, { "title": "Corporate Tax registration for natural persons with Business", "text": "The FTA guide states that a natural person is within Corporate Tax only where Business or Business Activity conducted in the UAE has Turnover above AED 1 million in a Gregorian calendar year. Employment income alone is treated differently.", "source_url": "https://tax.gov.ae/Datafolder/Files/Guides/VAT/VAT%20Guides/Tax-Resident-and-TRC--18-10-2024.pdf" } ], "social_security": null, "living_base": "The right to live in the UAE comes from a Residence Permit issued by the competent authorities, which the Cabinet Decision distinguishes from temporary entry permits for travel, tourism or medical treatment. Holding a residence permit is one condition of the 90-day test but does not by itself make a person tax resident.", "citizenship": "UAE nationality is governed by federal law and is not covered in detail here. Check the Federal Authority for Identity, Citizenship, Customs and Port Security for current rules.", "questions": [ "Which 12-month period should be used to count my days for the 183-day or 90-day test?", "Do I have a Permanent Place of Residence or employment in the UAE as the Ministerial Decision defines them?", "Could any of my days in the UAE be disregarded as exceptional circumstances?", "Which documents would the FTA expect for a Tax Residency Certificate application in my case?", "If another country also treats me as resident, how would a tax treaty tie-breaker apply?", "Does any Business I run in the UAE bring me within Corporate Tax?", "Would a UAE Tax Residency Certificate change how my home country treats me?" ], "authorities": [ { "title": "Federal Tax Authority", "url": "https://tax.gov.ae/en/" }, { "title": "Ministry of Finance", "url": "https://mof.gov.ae/" }, { "title": "Federal Authority for Identity, Citizenship, Customs and Port Security", "url": "https://icp.gov.ae/en/" } ], "sources": [ { "title": "Cabinet Decision No. 85 of 2022 on Determination of Tax Residency (unofficial translation)", "url": "https://tax.gov.ae/Datafolder/Files/Legislation/Corporate%20Tax/Cabinet%20Decision%2085%20of%202022%20-%20For%20publishing.pdf", "type": "primary-law" }, { "title": "Ministerial Decision No. 27 of 2023 on Implementation of Certain Provisions of Cabinet Decision No. 85 of 2022", "url": "https://mof.gov.ae/wp-content/uploads/2023/03/Ministerial-Decision-27-of-2023-of-Tax-Residency.pdf", "type": "primary-law" }, { "title": "Tax Resident and Tax Residency Certificate Tax Procedures Guide (TPGTR1, October 2024)", "url": "https://tax.gov.ae/Datafolder/Files/Guides/VAT/VAT%20Guides/Tax-Resident-and-TRC--18-10-2024.pdf", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "ar", "name": "Argentina", "slug": "argentina", "region": "South America", "flag": "🇦🇷", "tax_year": "1 January to 31 December", "tax_basis": "residence", "summary": "Argentina taxes residents on all income obtained in the country or abroad and non-residents only on Argentine-source income, and its income tax law treats Argentine nationals as residents unless they have lost that status. Foreign nationals become resident through permanent residence or twelve months of stay under temporary migration permits, and residence is lost by gaining permanent residence abroad or staying abroad continuously for twelve months.", "residence_rules": [ { "id": "AR-RES-01", "title": "Argentine nationals are residents unless residence has been lost", "kind": "citizenship", "text": "Article 116 of the Income Tax Law (ordered text 2019) treats native or naturalized Argentine nationals as residents, except those who have lost residence under article 117. A 2026 amendment (Law 27.802, Boletín Oficial 6 March 2026) adds that foreign nationals who obtain Argentine citizenship through a relevant investment are not treated as tax residents by that naturalization alone; they are assessed as foreign nationals under the permanent-residence and twelve-month tests, unless they were already permanent residents.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Ley de Impuesto a las Ganancias, texto ordenado 2019 (Decreto 824/2019), artículo 116, texto actualizado", "source_url": "https://www.argentina.gob.ar/normativa/nacional/decreto-824-2019-332890/actualizacion", "source_type": "primary-law", "effective": "Ordered text 2019; investment-citizenship paragraphs in force from 6 March 2026", "checked": "2026-11-08" }, { "id": "AR-RES-02", "title": "Foreign nationals: permanent residence or twelve months on temporary permits", "kind": "registration", "text": "Foreign nationals are residents once they obtain permanent residence in Argentina, or when they have stayed in the country for twelve months under temporary migration authorizations; temporary absences within the limits of the regulations do not break continuity. People without permanent residence whose stay does not imply an intention to remain habitually may document the reasons. Resident status takes effect from the first day of the month after permanent residence is obtained or the twelve-month period is completed.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Ley de Impuesto a las Ganancias, texto ordenado 2019, artículo 116, inciso b)", "source_url": "https://www.argentina.gob.ar/normativa/nacional/decreto-824-2019-332890/actualizacion", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "AR-RES-03", "title": "Loss of residence: permanent residence abroad or twelve months abroad", "kind": "registration", "text": "Residents lose resident status when they acquire permanent residence in a foreign state under that state's migration rules or, if that has not happened first, when they stay abroad continuously for twelve months; temporary presences in Argentina within regulatory limits do not break the period. People absent for reasons that do not imply an intention to live abroad habitually may document that. Loss takes effect from the first day of the month after the relevant event, and official representatives of the State abroad keep resident status.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Ley de Impuesto a las Ganancias, texto ordenado 2019, artículos 117 y 118", "source_url": "https://www.argentina.gob.ar/normativa/nacional/decreto-824-2019-332890/actualizacion", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "AR-RES-04", "title": "Double residence: home, vital interests, habitual abode, nationality", "kind": "ties", "text": "When a person who obtained permanent residence abroad, or lost Argentine residence, is also treated as resident elsewhere but keeps living in Argentina or re-enters to stay, article 122 treats them as resident if they keep a permanent home in Argentina; if they have permanent homes in both countries, if their centre of vital interests is in Argentina; failing that, if they spend more time in Argentina than in the other state over the period set by regulation; and, if time is equal, if they are Argentine nationals.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Ley de Impuesto a las Ganancias, texto ordenado 2019, artículo 122", "source_url": "https://www.argentina.gob.ar/normativa/nacional/decreto-824-2019-332890/actualizacion", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Article 119 requires a person who loses residence to show the tax authority (or, if already abroad, the Argentine consulate, which informs the authority) that residence abroad was acquired and that obligations on Argentine and foreign income were met for the part of the fiscal year up to the end of the month after the change. From the date the loss takes effect, the person is treated as a foreign beneficiary for Argentine-source income and must tell withholding agents (article 120). Relates to AR-RES-03.", "reporting": [ { "title": "Accreditation of loss of residence", "text": "People who lose Argentine tax residence must accredit the loss and the fulfilment of obligations for the part-year before the tax authority, or before the consulate if the loss happens after leaving, in the form set by the tax authority.", "source_url": "https://www.argentina.gob.ar/normativa/nacional/decreto-824-2019-332890/actualizacion" }, { "title": "Notice to withholding agents", "text": "After loss of residence takes effect, the person must tell the relevant withholding agents of the change of residence so that the non-resident withholding regime is applied.", "source_url": "https://www.argentina.gob.ar/normativa/nacional/decreto-824-2019-332890/actualizacion" } ], "social_security": null, "living_base": "The Migration Law admits foreign nationals as permanent residents, temporary residents or transitory residents, with the Dirección Nacional de Migraciones deciding changes of category. Migration status and tax residence interact here: permanent residence makes a foreign national a tax resident from the following month, and twelve months on temporary permits can do the same.", "citizenship": "The updated text of Citizenship Law 346 on argentina.gob.ar, as changed by Decree 366/2025, lets foreign nationals over 18 naturalize after two years of continuous and legal residence before the application, where continuous means no departure abroad during that period, or after making a relevant investment regardless of residence time, with the Dirección Nacional de Migraciones granting the letter of citizenship. Check the current status of these changes before relying on them. Whether Argentines keep their nationality on taking another one was not verified for this record.", "questions": [ "As an Argentine national living abroad, have I lost Argentine tax residence under article 117, and from which month?", "What documents would show that I acquired permanent residence abroad, and how do I accredit the loss before the tax authority or a consulate?", "As a foreign national, when would my twelve months on temporary permits make me resident, and which absences count?", "How would the double-residence rules in article 122 apply if I keep a home in Argentina?", "If I obtained citizenship through investment, how do the 2026 amendments affect my tax residence?", "Which Argentine withholding agents must I notify after a change of residence?", "How would a tax treaty between Argentina and my other country of residence apply, if one exists?" ], "authorities": [ { "title": "Agencia de Recaudación y Control Aduanero (ARCA, formerly AFIP)", "url": "https://www.arca.gob.ar" }, { "title": "Dirección Nacional de Migraciones", "url": "https://www.argentina.gob.ar/interior/migraciones" } ], "sources": [ { "title": "Decreto 824/2019 – Impuesto a las Ganancias, texto ordenado 2019 (texto actualizado)", "url": "https://www.argentina.gob.ar/normativa/nacional/decreto-824-2019-332890/actualizacion", "type": "primary-law" }, { "title": "Decreto 824/2019 – Impuesto a las Ganancias, texto ordenado 2019 (texto original)", "url": "https://www.argentina.gob.ar/normativa/nacional/decreto-824-2019-332890/texto", "type": "primary-law" }, { "title": "Ley 346 – Ciudadanía (texto actualizado)", "url": "https://www.argentina.gob.ar/normativa/nacional/ley-346-48854/actualizacion", "type": "primary-law" }, { "title": "Ley 25.871 – Migraciones (texto actualizado)", "url": "https://www.argentina.gob.ar/normativa/nacional/ley-25871-92016/actualizacion", "type": "primary-law" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "au", "name": "Australia", "slug": "australia", "region": "Oceania", "flag": "🇦🇺", "tax_year": "Income year (1 July to 30 June)", "tax_basis": "residence", "summary": "Australia's primary test is whether a person resides in Australia in the ordinary sense, judged on overall circumstances. If not, three statutory tests can still make a person resident: domicile, the 183-day test and the Commonwealth superannuation test. The ATO stresses that its rules differ from Home Affairs rules, so a visa or citizenship does not settle tax residence.", "residence_rules": [ { "id": "AU-RES-01", "title": "Resides test", "kind": "ties", "text": "The primary test is whether you reside in Australia according to the ordinary meaning of the word. Factors include physical presence, intention and purpose, family, business or employment ties, the location of assets, and social and living arrangements. If you reside in Australia, the other tests do not need to be applied.", "threshold_days": null, "window": null, "day_method": null, "source_title": "ATO: Your tax residency", "source_url": "https://www.ato.gov.au/individuals-and-families/coming-to-australia-or-going-overseas/your-tax-residency", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "AU-RES-02", "title": "Domicile test", "kind": "registration", "text": "A person is a resident if their domicile, their permanent home in law, is in Australia, unless the Commissioner is satisfied their permanent place of abode is outside Australia. Domicile can be of origin or of choice.", "threshold_days": null, "window": null, "day_method": null, "source_title": "ATO: Your tax residency", "source_url": "https://www.ato.gov.au/individuals-and-families/coming-to-australia-or-going-overseas/your-tax-residency", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "AU-RES-03", "title": "183-day test", "kind": "day-count", "text": "A person is a resident under this test if they are actually present in Australia for more than half the income year, continuously or with breaks, unless it is established that their usual place of abode is outside Australia and they have no intention of taking up residence.", "threshold_days": 183, "window": "tax-year", "day_method": null, "source_title": "ATO: Your tax residency", "source_url": "https://www.ato.gov.au/individuals-and-families/coming-to-australia-or-going-overseas/your-tax-residency", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "AU-RES-04", "title": "Commonwealth superannuation test", "kind": "registration", "text": "Australian Government employees at Australian posts overseas who are contributing members of the CSS or PSS, and their spouses and children under 16, are residents regardless of other factors. The test does not apply to PSSAP members.", "threshold_days": null, "window": null, "day_method": null, "source_title": "ATO: Your tax residency", "source_url": "https://www.ato.gov.au/individuals-and-families/coming-to-australia-or-going-overseas/your-tax-residency", "source_type": "official-guidance", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Relates to AU-RES-01. If status changes from resident to foreign resident during the income year, the ATO says you are taxed at resident rates with the resident income threshold pro-rated for the months resident. From the date you cease to be resident, foreign-source income need not be returned, and Australian interest, dividends and royalties received afterwards are subject to final withholding tax. The ATO also has separate guidance on capital gains tax for foreign residents.", "reporting": [ { "title": "Worldwide income for residents", "text": "An Australian resident for tax purposes must declare all income earned in Australia and overseas in the tax return.", "source_url": "https://www.ato.gov.au/individuals-and-families/coming-to-australia-or-going-overseas/your-tax-residency" } ], "social_security": null, "living_base": "The right to live in Australia comes from visas granted by the Department of Home Affairs, including permanent visas. The ATO says you can be a tax resident without being a citizen or permanent resident, and you may hold a visa yet not be a tax resident; some visa holders fall into a separate temporary resident category.", "citizenship": "Citizenship by conferral generally requires permanent residence. Home Affairs states the general residence requirement as living in Australia on a valid visa for 4 years immediately before applying, holding a permanent visa for the last 12 months, and not being absent for more than 12 months in total in those 4 years, including no more than 90 days in the last 12 months. The position on dual citizenship is not stated here.", "questions": [ "Do my overall circumstances mean I reside in Australia in the ordinary sense?", "If I leave Australia, have I established a permanent place of abode overseas for the domicile test?", "If I spend more than half the income year in Australia, is my usual place of abode elsewhere?", "Am I a temporary resident for tax purposes, and what follows from that?", "What capital gains tax consequences could follow from ceasing to be a resident?", "How would a tax treaty tie-breaker apply if another country also treats me as resident?", "How should I report a year in which my residency status changed?" ], "authorities": [ { "title": "Australian Taxation Office", "url": "https://www.ato.gov.au/" }, { "title": "Department of Home Affairs", "url": "https://immi.homeaffairs.gov.au/" } ], "sources": [ { "title": "Your tax residency (ATO, last updated 3 June 2026)", "url": "https://www.ato.gov.au/individuals-and-families/coming-to-australia-or-going-overseas/your-tax-residency", "type": "official-guidance" }, { "title": "Australia: Information on residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Australia-Residency.pdf", "type": "official-guidance" }, { "title": "Become an Australian citizen (by conferral): Permanent residents (Department of Home Affairs)", "url": "https://immi.homeaffairs.gov.au/citizenship/become-a-citizen/permanent-resident", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "bg", "name": "Bulgaria", "slug": "bulgaria", "region": "Europe", "flag": "🇧🇬", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "residence", "summary": "Bulgaria treats an individual as tax resident, whatever their citizenship, if they have a permanent address in Bulgaria, stay there more than 183 days in a 12-month period, are sent abroad by the Bulgarian state or a Bulgarian enterprise, or have their centre of vital interests in Bulgaria. A permanent address alone is not enough if the person's centre of vital interests is outside Bulgaria.", "residence_rules": [ { "id": "BG-RES-01", "title": "Permanent address in Bulgaria", "kind": "registration", "text": "Under Article 4 of the Personal Income Taxes Act, a person with a permanent address in Bulgaria is a local (resident) individual for tax purposes. A person who has a permanent address in Bulgaria but whose centre of vital interests is not in the country is not treated as resident.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Местни и чужди лица - Национална агенция за приходите", "source_url": "https://nra.bg/wps/portal/nra/taxes/godishen-danak-varhu-dohdite/mestni-i-chuzhdi-litsa", "source_type": "official-guidance", "effective": "Personal Income Taxes Act, Article 4", "checked": "2026-11-08" }, { "id": "BG-RES-02", "title": "More than 183 days in a 12-month period", "kind": "day-count", "text": "A person who stays in Bulgaria for more than 183 days in any 12-month period is resident, and is regarded as resident for the year in which the stay exceeds 183 days. The day of leaving and the day of entering the country each count as days of stay in Bulgaria. A stay only for education or medical treatment is not counted as a stay in Bulgaria.", "threshold_days": 183, "window": "rolling-12-months", "day_method": "official-guidance", "source_title": "Местни и чужди лица - Национална агенция за приходите", "source_url": "https://nra.bg/wps/portal/nra/taxes/godishen-danak-varhu-dohdite/mestni-i-chuzhdi-litsa", "source_type": "official-guidance", "effective": "Personal Income Taxes Act, Article 4", "checked": "2026-11-08" }, { "id": "BG-RES-03", "title": "Centre of vital interests in Bulgaria", "kind": "ties", "text": "A person whose centre of vital interests is in Bulgaria is resident. This applies when the person's interests are closely connected with the country, taking into account family, property, the place from which they carry out employment, professional or business activity, and the place from which they manage their property.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Bulgaria - Information on Residency for tax purposes (OECD AEOI portal)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Bulgaria-Tax-Residency.pdf", "source_type": "official-guidance", "effective": "Personal Income Taxes Act, Article 4", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Under BG-RES-02, a person is regarded as resident for the year in which their stay exceeds 183 days. The sources checked do not set out departure rules; check the current NRA guidance.", "reporting": [], "social_security": "Bulgaria applies the EU rules on social security coordination: a person is generally covered by one country's system at a time, and a PD A1 form can show continued home-country cover during a temporary posting. Check national contribution rules with the Bulgarian social security authorities.", "living_base": "EU citizens can stay in Bulgaria for up to three months without registering and may need to register for longer stays; after five years of continuous lawful residence they acquire the right of permanent residence. Non-EU nationals generally need a visa or residence permit, handled by the Migration Directorate of the Ministry of Interior. A permit or a registered address does not by itself decide tax residence; BG-RES-01 shows that a permanent address without a centre of vital interests in Bulgaria is not enough.", "citizenship": "Bulgarian citizenship is acquired mainly by descent or by naturalization after a period of lawful residence, with other routes set by national law. This record has not verified the current residence period or the position on dual citizenship; check the competent Bulgarian authority's current guidance.", "questions": [ "Do I have a permanent address in Bulgaria, and where is my centre of vital interests?", "How many days, counting days of entry and exit, have I stayed in Bulgaria in each 12-month period, and in which year does my stay exceed 183 days?", "Do any of my days in Bulgaria fall under the exclusion for education or medical treatment?", "Does another country also treat me as tax resident, and how does the tax treaty decide my residence?", "What evidence would the NRA ask for before issuing a certificate of residence for treaty purposes?", "What happens to my Bulgarian residence status in the year I leave Bulgaria?" ], "authorities": [ { "title": "National Revenue Agency (NRA)", "url": "https://nra.bg/" }, { "title": "Ministry of Interior (Migration Directorate)", "url": "https://www.mvr.bg/" } ], "sources": [ { "title": "Местни и чужди лица - Национална агенция за приходите", "url": "https://nra.bg/wps/portal/nra/taxes/godishen-danak-varhu-dohdite/mestni-i-chuzhdi-litsa", "type": "official-guidance" }, { "title": "Bulgaria - Information on Residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Bulgaria-Tax-Residency.pdf", "type": "official-guidance" }, { "title": "Social security cover when you live or work in another EU country - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights when living abroad in the EU - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "br", "name": "Brazil", "slug": "brazil", "region": "South America", "flag": "🇧🇷", "tax_year": "Calendar year (ano-calendário)", "tax_basis": "residence", "summary": "Brazil taxes residents on income from Brazilian and foreign sources and taxes non-residents on Brazilian-source income, and since 1 January 2024 Law 14.754/2023 has set specific annual rules for residents' foreign financial investments and controlled foreign entities. Residence turns on permanent residence, visa type and, for temporary-visa holders, completing 184 days in Brazil within up to twelve months; leaving requires a formal exit communication or twelve consecutive months abroad.", "residence_rules": [ { "id": "BR-RES-01", "title": "Permanent residence, permanent visa or employment on arrival", "kind": "registration", "text": "Receita Federal treats as resident a person who lives in Brazil on a permanent basis, and a person who enters with a permanent visa from the date of arrival. A person entering on a temporary visa to work with an employment relationship is resident from arrival, and a temporary-visa holder becomes resident on the date a permanent visa or employment relationship is obtained if that happens before the 184-day count is reached. A Brazilian who had become non-resident and returns with the intention to live in Brazil is resident from the date of arrival.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Perguntas e Respostas IRPF 2026, questions 114 and 128 (Receita Federal)", "source_url": "https://www.gov.br/receitafederal/pt-br/centrais-de-conteudo/publicacoes/perguntas-e-respostas/dirpf/p-r-irpf-2026-v1-00-2026-04-23.pdf", "source_type": "official-guidance", "effective": "Law 9.718/1998, art. 12; IN SRF 208/2002, art. 2", "checked": "2026-11-08" }, { "id": "BR-RES-02", "title": "Temporary visa: resident on completing 184 days within up to twelve months", "kind": "day-count", "text": "A person who enters Brazil on a temporary visa (other than for employment) becomes resident on the date they complete 184 days of presence, consecutive or not, within a period of up to twelve months. Someone who stays up to 183 days in that period remains non-resident. If 184 days are not reached within twelve months, a new twelve-month period starts from the next entry after the one that began the previous count.", "threshold_days": 184, "window": "rolling-12-months", "day_method": null, "source_title": "Perguntas e Respostas IRPF 2026, questions 114 and 115 (Receita Federal)", "source_url": "https://www.gov.br/receitafederal/pt-br/centrais-de-conteudo/publicacoes/perguntas-e-respostas/dirpf/p-r-irpf-2026-v1-00-2026-04-23.pdf", "source_type": "official-guidance", "effective": "Law 9.718/1998, art. 12; IN SRF 208/2002, arts. 2 and 3", "checked": "2026-11-08" }, { "id": "BR-RES-03", "title": "Leaving Brazil: exit communication or twelve consecutive months abroad", "kind": "registration", "text": "A person who leaves permanently becomes non-resident on the date of departure when the Comunicação de Saída Definitiva do País (CSDP) or the Declaração de Saída Definitiva do País (DSDP) is filed. A person who leaves temporarily, or leaves permanently without filing the exit communication, stays resident during the first twelve consecutive months abroad and becomes non-resident from the day after completing twelve consecutive months of absence.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Perguntas e Respostas IRPF 2026, questions 114 and 115 (Receita Federal)", "source_url": "https://www.gov.br/receitafederal/pt-br/centrais-de-conteudo/publicacoes/perguntas-e-respostas/dirpf/p-r-irpf-2026-v1-00-2026-04-23.pdf", "source_type": "official-guidance", "effective": "IN SRF 208/2002, arts. 3, 11 and 11-A", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "On departure, Receita Federal guidance says the CSDP is due by the last day of February of the year after leaving and the DSDP by the normal annual return deadline. The year of departure is the year the person left permanently or, for a departure that began as temporary, the year non-residence arose after twelve consecutive months abroad. After the exit, foreign income no longer has to be declared and Brazilian-source income is taxed under the non-resident rules, and Brazilian payers must be told of the change. Relates to BR-RES-03.", "reporting": [ { "title": "Exit communication and exit return (CSDP and DSDP)", "text": "People who leave Brazil permanently, or become non-resident after a temporary departure, file the Comunicação de Saída Definitiva do País and the Declaração de Saída Definitiva do País. Receita Federal guidance sets out separate steps for people who missed the deadline.", "source_url": "https://www.gov.br/receitafederal/pt-br/assuntos/noticias/2025/outubro/receita-federal-alerta-para-fake-news-sobre-rastreamento-de-brasileiros-que-passaram-a-residir-no-exterior/ne-saida-definitiva-do-pais.pdf" }, { "title": "Annual return triggers tied to foreign assets", "text": "For the 2026 return, Receita Federal lists filing triggers that include holding assets over R$800,000 on 31 December, becoming resident during the year, holding a trust governed by foreign law, and having income or losses from foreign financial investments or profits from foreign entities under Law 14.754/2023.", "source_url": "https://www.gov.br/receitafederal/pt-br/centrais-de-conteudo/publicacoes/perguntas-e-respostas/dirpf/p-r-irpf-2026-v1-00-2026-04-23.pdf" } ], "social_security": "Brazil appears on the CRA's list of countries with a social security agreement with Canada; check the INSS and each agreement for coverage and terms.", "living_base": "Foreign nationals live in Brazil under a residence authorization; the Ministry of Justice explains that naturalization requires first obtaining residence for an indefinite period registered with the Federal Police. A residence authorization does not by itself settle tax residence, which follows the Receita Federal tests on visa type, employment and days of presence.", "citizenship": "Ordinary naturalization requires residence for an indefinite period, with a standard residence period of four years. The Ministry of Justice lists a one-year period for applicants with a Brazilian child, a Brazilian spouse or stable partner, or who are nationals of a Portuguese-speaking country, and a two-year period for recognized stateless persons and for relevant service or notable ability. Whether Brazilians keep their nationality on acquiring another one was not verified from an official page for this record.", "questions": [ "On what date did I, or will I, become a Brazilian tax resident given my visa type and employment status?", "How are my days of presence counted for the 184-day test, and when does a new twelve-month period start?", "Should I file the CSDP and DSDP when I leave, and what happens to my residence if I do not?", "How does Law 14.754/2023 treat my foreign financial investments, controlled foreign entities or trusts as a resident?", "Which Brazilian payers must I notify of a change in residence, and how will withholding change?", "How would a tax treaty between Brazil and my other country of residence settle a dual-residence situation?", "Which naturalization period applies to me, and how are trips abroad counted against it?" ], "authorities": [ { "title": "Receita Federal do Brasil", "url": "https://www.gov.br/receitafederal/pt-br" }, { "title": "Ministério da Justiça e Segurança Pública – Migrações", "url": "https://www.gov.br/mj/pt-br/assuntos/seus-direitos/migracoes" }, { "title": "Polícia Federal – Imigração", "url": "https://www.gov.br/pf/pt-br/assuntos/imigracao" } ], "sources": [ { "title": "Perguntas e Respostas IRPF 2026 (Receita Federal)", "url": "https://www.gov.br/receitafederal/pt-br/centrais-de-conteudo/publicacoes/perguntas-e-respostas/dirpf/p-r-irpf-2026-v1-00-2026-04-23.pdf", "type": "official-guidance" }, { "title": "Nota Executiva: Orientações para Regularização Fiscal de Residentes no Exterior (Receita Federal)", "url": "https://www.gov.br/receitafederal/pt-br/assuntos/noticias/2025/outubro/receita-federal-alerta-para-fake-news-sobre-rastreamento-de-brasileiros-que-passaram-a-residir-no-exterior/ne-saida-definitiva-do-pais.pdf", "type": "official-guidance" }, { "title": "Comunicação de Saída Definitiva do País — Receita Federal", "url": "https://www.gov.br/receitafederal/pt-br/assuntos/meu-imposto-de-renda/preenchimento/dsdp", "type": "official-guidance" }, { "title": "Naturalização ordinária — Ministério da Justiça e Segurança Pública", "url": "https://www.gov.br/mj/pt-br/assuntos/seus-direitos/migracoes/naturalizacao/o-que-e-naturalizacao/naturalizacao-ordinaria", "type": "official-guidance" }, { "title": "What is the purpose of international social security agreements? (CRA)", "url": "https://www.canada.ca/en/revenue-agency/services/tax/canada-pension-plan-cpp-employment-insurance-ei-rulings/international-social-security-agreements-canada-pension-plan/what-purpose-international-social-security-agreements.html", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "ca", "name": "Canada", "slug": "canada", "region": "North America", "flag": "🇨🇦", "tax_year": "Calendar year", "tax_basis": "residence", "summary": "Canada taxes residents on worldwide income, and residence is decided on all the facts, led by residential ties such as a home, a spouse or common-law partner and dependants in Canada. A separate deemed-residence rule catches people without those ties who sojourn in Canada for 183 days or more in a calendar year, and leaving Canada can trigger a deemed disposition of property.", "residence_rules": [ { "id": "CA-RES-01", "title": "Factual residence: significant and secondary residential ties", "kind": "ties", "text": "The CRA decides residence case by case. Its folio lists three ties that will almost always be significant: a dwelling place in Canada, a spouse or common-law partner in Canada, and dependants in Canada. Secondary ties such as personal property, social ties, provincial health coverage and a driver's licence are weighed together. A factual resident is taxed on worldwide income.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Income Tax Folio S5-F1-C1, Determining an Individual's Residence Status", "source_url": "https://www.canada.ca/en/revenue-agency/services/tax/technical-information/income-tax/income-tax-folios-index/series-5-international-residency/folio-1-residency/income-tax-folio-s5-f1-c1-determining-individual-s-residence-status.html", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "CA-RES-02", "title": "Deemed residence: sojourning 183 days or more in a calendar year", "kind": "day-count", "text": "Under paragraph 250(1)(a) of the Income Tax Act, a person who is not factually resident but sojourns in Canada for 183 days or more in a calendar year is deemed resident for the entire year and taxed on worldwide income. The CRA counts any part of a day as a day of sojourn. Whether a person is sojourning is a question of fact: a commuter who goes home each night is not, while a person on vacation in Canada is.", "threshold_days": 183, "window": "calendar-year", "day_method": "any-part", "source_title": "Income Tax Folio S5-F1-C1, Determining an Individual's Residence Status (paragraphs 1.32 and 1.33)", "source_url": "https://www.canada.ca/en/revenue-agency/services/tax/technical-information/income-tax/income-tax-folios-index/series-5-international-residency/folio-1-residency/income-tax-folio-s5-f1-c1-determining-individual-s-residence-status.html", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "CA-RES-03", "title": "Treaty tie-breaker and deemed non-residence under subsection 250(5)", "kind": "ties", "text": "If a tax treaty's tie-breaker rules make a person resident of the other country, subsection 250(5) treats the person as not resident in Canada for all purposes of the Act from that time. The CRA notes that treaty tie-breakers usually look first at where the person has a permanent home. People can ask the CRA for an opinion using Form NR73 (leaving Canada) or Form NR74 (entering Canada).", "threshold_days": null, "window": null, "day_method": null, "source_title": "Income Tax Folio S5-F1-C1, Determining an Individual's Residence Status (paragraphs 1.37, 1.46 and 1.54)", "source_url": "https://www.canada.ca/en/revenue-agency/services/tax/technical-information/income-tax/income-tax-folios-index/series-5-international-residency/folio-1-residency/income-tax-folio-s5-f1-c1-determining-individual-s-residence-status.html", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Part-year residence: the folio says residence generally ends on the date a person severs all residential ties, usually the latest date on which the person, a spouse or common-law partner and dependants have left, and begins on the date ties are established on entry (CA-RES-01). On emigration a person is treated as having disposed of most property at fair market value; tax on the resulting gains is called departure tax and is reported on Form T1243. An election to defer it can be made with Form T1244 by April 30 of the year after emigration. If total fair market value of all property was more than $25,000 on leaving, Form T1161 must be filed with the return.", "reporting": [ { "title": "Form T1135, Foreign Income Verification Statement", "text": "The CRA says Canadian residents must file Form T1135 when the cost amount of their specified foreign property exceeds $100,000. The threshold is based on cost amount, not fair market value.", "source_url": "https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/information-been-moved/foreign-reporting/questions-answers-about-form-t1135.html" }, { "title": "Form T1161, List of Properties by an Emigrant of Canada", "text": "An emigrant whose property had a total fair market value of more than $25,000 when leaving must list property inside and outside Canada on Form T1161 by the filing due date, even if no return is otherwise required.", "source_url": "https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-entering-canada-non-residents/dispositions-property.html" } ], "social_security": "Canada has international social security agreements that aim to stop workers paying into two systems for the same work and that coordinate pension programs. The CRA's list includes the United States, Mexico, Brazil, Chile and Uruguay; check the CRA table for the current list and terms.", "living_base": "Canada's immigration routes divide into temporary stays (visitor status, study permits and temporary work permits) and permanent residence through programs such as Express Entry or family sponsorship. An immigration status does not decide tax residence: the CRA looks at residential ties and, for people without them, at days of sojourn.", "citizenship": "Adults apply for citizenship after being physically present in Canada for at least 1,095 days (3 years) during a 5-year eligibility period. A person with a Canadian parent or grandparent may already be a citizen by descent and can apply for a citizenship certificate. IRCC says Canadians are allowed to take foreign citizenship while keeping Canadian citizenship.", "questions": [ "Which of my ties to Canada would the CRA treat as significant, and which secondary ties remain after a move?", "On what date would my Canadian residence end or begin given when my home, spouse or partner and dependants move?", "Could I be deemed resident by sojourning 183 days or more in a calendar year, and how are part days counted?", "Would a treaty tie-breaker treat me as resident of another country, and what would that mean under subsection 250(5)?", "Which of my assets would be caught by the deemed disposition on emigration, and is a T1244 deferral election worth discussing?", "Do I need to file Form T1135 or Form T1161, and how is cost amount worked out for my foreign property?", "Does a social security agreement cover my work between Canada and another country?" ], "authorities": [ { "title": "Canada Revenue Agency (CRA)", "url": "https://www.canada.ca/en/revenue-agency.html" }, { "title": "Immigration, Refugees and Citizenship Canada (IRCC)", "url": "https://www.canada.ca/en/immigration-refugees-citizenship.html" } ], "sources": [ { "title": "Income Tax Folio S5-F1-C1, Determining an Individual's Residence Status", "url": "https://www.canada.ca/en/revenue-agency/services/tax/technical-information/income-tax/income-tax-folios-index/series-5-international-residency/folio-1-residency/income-tax-folio-s5-f1-c1-determining-individual-s-residence-status.html", "type": "official-guidance" }, { "title": "Dispositions of property for emigrants of Canada", "url": "https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-entering-canada-non-residents/dispositions-property.html", "type": "official-guidance" }, { "title": "Questions and answers about Form T1135", "url": "https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/information-been-moved/foreign-reporting/questions-answers-about-form-t1135.html", "type": "official-guidance" }, { "title": "What is the purpose of international social security agreements?", "url": "https://www.canada.ca/en/revenue-agency/services/tax/canada-pension-plan-cpp-employment-insurance-ei-rulings/international-social-security-agreements-canada-pension-plan/what-purpose-international-social-security-agreements.html", "type": "official-guidance" }, { "title": "Immigration and citizenship - Canada.ca", "url": "https://www.canada.ca/en/services/immigration-citizenship.html", "type": "official-guidance" }, { "title": "Canadian citizenship for adults and minor children: Who can apply", "url": "https://www.canada.ca/en/immigration-refugees-citizenship/services/canadian-citizenship/become-canadian-citizen/eligibility.html", "type": "official-guidance" }, { "title": "What is dual citizenship? (IRCC Help Centre)", "url": "https://ircc.canada.ca/english/helpcentre/answer.asp?qnum=356", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "ch", "name": "Switzerland", "slug": "switzerland", "region": "Europe", "flag": "🇨🇭", "tax_year": "1 January to 31 December", "tax_basis": "residence", "summary": "For the federal direct tax, a person is taxable on personal grounds if they have a tax domicile in Switzerland (staying with the intention of remaining permanently) or a tax stay, which arises after at least 30 days with gainful activity or at least 90 days without it, regardless of temporary interruptions. Cantons and communes levy their own income and wealth taxes under cantonal law, so the federal rules are only part of the picture.", "residence_rules": [ { "id": "CH-RES-01", "title": "Tax domicile: intention to remain permanently", "kind": "ties", "text": "A person has a tax domicile in Switzerland if they stay there with the intention of remaining permanently, or if federal law assigns them a special legal domicile there. This test does not depend on a day count.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Bundesgesetz über die direkte Bundessteuer (DBG), Art. 3", "source_url": "https://fedlex.data.admin.ch/filestore/fedlex.data.admin.ch/eli/cc/1991/1184_1184_1184/20260902/de/pdf-a/fedlex-data-admin-ch-eli-cc-1991-1184_1184_1184-20260902-de-pdf-a.pdf", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "CH-RES-02", "title": "Tax stay with gainful activity: 30 days", "kind": "day-count", "text": "A person has a tax stay in Switzerland if they remain there for at least 30 days and carry on a gainful activity, regardless of temporary interruptions. A person domiciled abroad who stays only to attend an educational institution or for care in a medical facility does not create a tax domicile or stay.", "threshold_days": 30, "window": null, "day_method": null, "source_title": "Bundesgesetz über die direkte Bundessteuer (DBG), Art. 3", "source_url": "https://fedlex.data.admin.ch/filestore/fedlex.data.admin.ch/eli/cc/1991/1184_1184_1184/20260902/de/pdf-a/fedlex-data-admin-ch-eli-cc-1991-1184_1184_1184-20260902-de-pdf-a.pdf", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "CH-RES-03", "title": "Tax stay without gainful activity: 90 days", "kind": "day-count", "text": "A person has a tax stay in Switzerland if they remain there for at least 90 days without carrying on a gainful activity, regardless of temporary interruptions. The same exception for study and medical care applies.", "threshold_days": 90, "window": null, "day_method": null, "source_title": "Bundesgesetz über die direkte Bundessteuer (DBG), Art. 3", "source_url": "https://fedlex.data.admin.ch/filestore/fedlex.data.admin.ch/eli/cc/1991/1184_1184_1184/20260902/de/pdf-a/fedlex-data-admin-ch-eli-cc-1991-1184_1184_1184-20260902-de-pdf-a.pdf", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": null, "reporting": [ { "title": "Taxation according to expenditure (lump-sum taxation, Art. 14 DBG)", "text": "At federal level, a person may pay a tax based on expenditure instead of income tax if they do not hold Swiss citizenship, are taxable on personal grounds for the first time or after an absence of at least ten years, and carry on no gainful activity in Switzerland; married couples living together must both meet the conditions. The tax base is annual living costs, with minimum amounts set in the law, and cantons apply their own rules, so check the cantonal law.", "source_url": "https://fedlex.data.admin.ch/filestore/fedlex.data.admin.ch/eli/cc/1991/1184_1184_1184/20260902/de/pdf-a/fedlex-data-admin-ch-eli-cc-1991-1184_1184_1184-20260902-de-pdf-a.pdf" } ], "social_security": "Switzerland applies EU coordination rules for social security with EU and EFTA states under the Agreement on the Free Movement of Persons, and has bilateral social security conventions with other countries, including Australia, Brazil, Canada, Japan and the United States, listed by the Federal Social Insurance Office. Only the legal texts and conventions decide individual cases.", "living_base": "EU and EFTA nationals generally move to Switzerland under the Agreement on the Free Movement of Persons, while others need a permit for a specific purpose such as work or family. A residence permit does not decide tax liability, which follows the tax domicile and tax stay rules.", "citizenship": "Ordinary naturalisation requires ten years of residence in Switzerland and a permanent residence permit (C permit); years spent in Switzerland between ages 8 and 18 count double, with at least six years of actual residence. Cantonal law also sets a minimum residence period of two to five years in the canton and commune. The State Secretariat for Migration states that dual nationality has been recognised without restriction since 1 January 1992.", "questions": [ "Would my stays in Switzerland create a tax domicile, or a tax stay under the 30-day or 90-day tests?", "Does any gainful activity I carry on in Switzerland change which day test applies?", "How does my canton and commune tax me, and how do cantonal rules differ from the federal rules?", "Would taxation according to expenditure be available in my canton, and what minimum tax base would apply?", "If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?", "Which social security system covers me under the free movement agreement or a bilateral agreement?" ], "authorities": [ { "title": "Swiss Federal Tax Administration (ESTV / AFC)", "url": "https://www.estv.admin.ch" }, { "title": "State Secretariat for Migration (SEM)", "url": "https://www.sem.admin.ch" }, { "title": "Federal Social Insurance Office (BSV / OFAS)", "url": "https://www.bsv.admin.ch" } ], "sources": [ { "title": "Bundesgesetz über die direkte Bundessteuer (DBG), SR 642.11, Stand 2 September 2026", "url": "https://fedlex.data.admin.ch/filestore/fedlex.data.admin.ch/eli/cc/1991/1184_1184_1184/20260902/de/pdf-a/fedlex-data-admin-ch-eli-cc-1991-1184_1184_1184-20260902-de-pdf-a.pdf", "type": "primary-law" }, { "title": "Ordinary naturalisation", "url": "https://www.sem.admin.ch/sem/en/home/integration-einbuergerung/schweizer-werden/ordentlich.html", "type": "official-guidance" }, { "title": "Dual nationality", "url": "https://www.sem.admin.ch/sem/en/home/integration-einbuergerung/schweizer-werden/doppelbuerger.html", "type": "official-guidance" }, { "title": "Informations sur les conventions bilatérales de sécurité sociale (Federal Social Insurance Office)", "url": "https://www.bsv.admin.ch/bsv/de/home/sozialversicherungen/int/grundlagen-und-abkommen.html", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "cl", "name": "Chile", "slug": "chile", "region": "South America", "flag": "🇨🇱", "tax_year": "Calendar year (año calendario: the twelve months ending 31 December)", "tax_basis": "residence", "summary": "Chile taxes persons domiciled or resident in Chile on income from any origin, whether the source is inside or outside the country, and non-residents only on Chilean-source income. A foreign national who establishes domicile or residence in Chile is taxed only on Chilean-source income during the first three years from entry, a period the Director Regional can extend in qualified cases.", "residence_rules": [ { "id": "CL-RES-01", "title": "More than 183 days within any twelve months", "kind": "day-count", "text": "The Tax Code defines a resident as any individual who stays in Chile, continuously or not, for one or more periods totalling more than 183 days within any twelve-month period.", "threshold_days": 183, "window": "rolling-12-months", "day_method": null, "source_title": "Código Tributario (Decreto Ley 830), artículo 8, número 8 (LeyChile)", "source_url": "https://www.leychile.cl/Consulta/obtxml?opt=7&idNorma=6374", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "CL-RES-02", "title": "Domicile kept while abroad: principal seat of business in Chile", "kind": "ties", "text": "The Income Tax Law taxes persons domiciled in Chile as well as residents. It says that an absence or lack of residence in the country does not cause loss of domicile when the person keeps the principal seat of their business in Chile, directly or indirectly.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Ley sobre Impuesto a la Renta (Decreto Ley 824), artículos 3 y 4 (LeyChile)", "source_url": "https://www.leychile.cl/Consulta/obtxml?opt=7&idNorma=6368", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "CL-RES-03", "title": "First three years for foreign nationals: Chilean-source income only", "kind": "registration", "text": "A foreign national who establishes domicile or residence in Chile is taxed only on Chilean-source income during the first three years counted from entry into the country. The Director Regional can extend this period in qualified cases. When the period or its extensions end, the general rule on income of any origin applies.", "threshold_days": null, "window": "multi-year", "day_method": null, "source_title": "Ley sobre Impuesto a la Renta (Decreto Ley 824), artículo 3", "source_url": "https://www.leychile.cl/Consulta/obtxml?opt=7&idNorma=6368", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": null, "reporting": [], "social_security": "Chile appears on the CRA's list of countries with a social security agreement with Canada; check the Chilean social security authorities and each agreement for coverage and terms.", "living_base": "Under Law 21.325 on Migration and Foreigners, temporary residence allows foreign nationals to settle in Chile for a limited time on grounds such as family ties or national policy interests. Definitive residence allows an indefinite stay and any lawful activity, and generally requires prior temporary residence. Migration residence and tax residence are separate tests.", "citizenship": "The Constitution (article 10) lists nationality by birth in Chile, by descent subject to conditions, by letter of naturalization under the law, and by special grace by law. Law 21.325 provides for qualified naturalization of definitive residents with two years of continuous residence who have a listed link, such as being the spouse of a Chilean for two years with the marriage registered in Chile, a relative of a Chilean up to the second degree, or a child of a former Chilean. Article 11 of the Constitution says nationality is lost by voluntary renunciation before a competent Chilean authority, which takes effect only if the person has already naturalized in a foreign country, and in some other listed cases.", "questions": [ "Did I stay in Chile for more than 183 days within any twelve-month period, counting separate stays together?", "Do I keep the principal seat of my business in Chile while living abroad?", "As a foreign national, when did my three-year period start, and which of my income items are Chilean-source?", "Could my situation qualify for an extension of the three-year period, and how is it requested?", "How would a tax treaty between Chile and my other country of residence resolve dual residence, if one applies?", "Which migration residence category fits my plans, and does it lead to definitive residence?", "Would a qualified naturalization route apply to me, or the general rules?" ], "authorities": [ { "title": "Servicio de Impuestos Internos (SII)", "url": "https://www.sii.cl" }, { "title": "Servicio Nacional de Migraciones", "url": "https://serviciomigraciones.cl" } ], "sources": [ { "title": "Código Tributario (Decreto Ley 830), LeyChile, Biblioteca del Congreso Nacional", "url": "https://www.leychile.cl/Consulta/obtxml?opt=7&idNorma=6374", "type": "primary-law" }, { "title": "Ley sobre Impuesto a la Renta (Decreto Ley 824), LeyChile, Biblioteca del Congreso Nacional", "url": "https://www.leychile.cl/Consulta/obtxml?opt=7&idNorma=6368", "type": "primary-law" }, { "title": "Constitución Política de la República, artículos 10 y 11, LeyChile", "url": "https://www.leychile.cl/Consulta/obtxml?opt=7&idNorma=242302", "type": "primary-law" }, { "title": "Ley 21.325 de Migración y Extranjería, LeyChile", "url": "https://www.leychile.cl/Consulta/obtxml?opt=7&idNorma=1158549", "type": "primary-law" }, { "title": "What is the purpose of international social security agreements? (CRA)", "url": "https://www.canada.ca/en/revenue-agency/services/tax/canada-pension-plan-cpp-employment-insurance-ei-rulings/international-social-security-agreements-canada-pension-plan/what-purpose-international-social-security-agreements.html", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "co", "name": "Colombia", "slug": "colombia", "region": "South America", "flag": "🇨🇴", "tax_year": "Taxable year (año o periodo gravable); confirm the period with DIAN", "tax_basis": "residence", "summary": "Colombia taxes resident individuals on national and foreign-source income and on assets held inside and outside the country. Residence follows a day count of more than 183 calendar days in any 365-day period, plus tests for Colombian nationals based on family, income, assets and proof of residence abroad, so a national can remain resident while living outside Colombia.", "residence_rules": [ { "id": "CO-RES-01", "title": "More than 183 calendar days in any 365 consecutive days", "kind": "day-count", "text": "Article 10 of the Estatuto Tributario treats as resident anyone present in Colombia, continuously or not, for more than 183 calendar days, including days of entry and exit, during any period of 365 consecutive calendar days. When the stay spans more than one taxable year, the person is resident from the second taxable year. The rule applies to nationals and foreign nationals alike.", "threshold_days": 183, "window": "rolling-12-months", "day_method": "official-guidance", "source_title": "Estatuto Tributario, artículo 10 (modificado por la Ley 1607 de 2012), Normograma DIAN", "source_url": "https://normograma.dian.gov.co/dian/compilacion/docs/estatuto_tributario.htm", "source_type": "primary-law", "effective": "Article 10 as amended by Law 1607 of 2012", "checked": "2026-11-08" }, { "id": "CO-RES-02", "title": "Colombian nationals: family, income, assets and proof of foreign residence", "kind": "ties", "text": "Colombian nationals are also resident for a taxable year if any of these apply: a spouse or permanent partner not legally separated, or dependent minor children, are tax residents in Colombia; 50% or more of their income is Colombian-source; 50% or more of their assets are administered in Colombia; 50% or more of their assets are deemed held in Colombia; they fail to prove foreign tax residence when asked by DIAN; or they are tax resident in a jurisdiction listed as a tax haven. Nationals proving residence abroad do so with a tax residence certificate from the other country.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Estatuto Tributario, artículo 10, numeral 3 y parágrafo", "source_url": "https://normograma.dian.gov.co/dian/compilacion/docs/estatuto_tributario.htm", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "CO-RES-03", "title": "Exception for nationals whose income or assets are mainly in their domicile country", "kind": "ties", "text": "A paragraph added by Law 1739 of 2014 says nationals who meet one of the numeral 3 tests are not residents if 50% or more of their annual income has its source in the jurisdiction where they are domiciled, or 50% or more of their assets are located there. The government sets how this is proven.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Estatuto Tributario, artículo 10, parágrafo adicionado por la Ley 1739 de 2014", "source_url": "https://normograma.dian.gov.co/dian/compilacion/docs/estatuto_tributario.htm", "source_type": "primary-law", "effective": "Law 1739 of 2014", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "When a qualifying stay of more than 183 days spans two taxable years, the person is treated as resident from the second taxable year (CO-RES-01). No separate departure procedure was verified for this record; check DIAN guidance for the year of arrival or departure.", "reporting": [ { "title": "Annual declaration of assets abroad (declaración anual de activos en el exterior)", "text": "Income taxpayers taxed on national and foreign income and on worldwide assets who hold assets abroad of any kind must file this declaration. Assets held on 1 January with a value above 3,580 UVT are listed individually with their jurisdiction and type; smaller ones are declared in aggregate by jurisdiction.", "source_url": "https://normograma.dian.gov.co/dian/compilacion/docs/estatuto_tributario.htm" } ], "social_security": null, "living_base": "Foreign nationals live in Colombia under visas issued by the Ministry of Foreign Affairs; the nationality law counts residence for naturalization from the date a resident visa (Visa de Residente) is issued. A visa does not settle tax residence, which follows the day count and national-specific tests in article 10 of the Estatuto Tributario.", "citizenship": "Under Law 2332 of 2023, foreign nationals apply to the Ministry of Foreign Affairs after five continuous years of domicile with a resident visa, reduced to two years for spouses or permanent partners of Colombians, parents of Colombian children, or where reciprocity applies; Latin Americans and Caribbeans by birth may instead ask to be registered as Colombians. The Constitution (article 96) says Colombian nationality is not lost by acquiring another nationality and that nationals by adoption need not renounce their nationality of origin.", "questions": [ "How many days was I in Colombia in each 365-day period, counting entry and exit days, and in which taxable year would residence start?", "As a Colombian national abroad, do any of the family, income or asset tests make me resident for the year?", "Could the exception for nationals with most of their income or assets in their domicile country apply to me, and how is it proven?", "What tax residence certificate from my other country would DIAN accept?", "Do I need to file the annual declaration of assets abroad, and which assets must be listed individually?", "How would a tax treaty between Colombia and my other country of residence resolve dual residence, if one applies?", "Which visa category starts the residence period that counts toward naturalization?" ], "authorities": [ { "title": "Dirección de Impuestos y Aduanas Nacionales (DIAN)", "url": "https://www.dian.gov.co" }, { "title": "Ministerio de Relaciones Exteriores (Cancillería) – Visas", "url": "https://www.cancilleria.gov.co" }, { "title": "Migración Colombia", "url": "https://www.migracioncolombia.gov.co" } ], "sources": [ { "title": "Estatuto Tributario (Decreto 624 de 1989), compilación Normograma DIAN", "url": "https://normograma.dian.gov.co/dian/compilacion/docs/estatuto_tributario.htm", "type": "primary-law" }, { "title": "Ley 2332 de 2023 – nacionalidad colombiana (Secretaría del Senado)", "url": "http://www.secretariasenado.gov.co/senado/basedoc/ley_2332_2023.html", "type": "primary-law" }, { "title": "Constitución Política de 1991, artículo 96 (Secretaría del Senado)", "url": "http://www.secretariasenado.gov.co/senado/basedoc/constitucion_politica_1991_pr002.html", "type": "primary-law" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "cr", "name": "Costa Rica", "slug": "costa-rica", "region": "Central America", "flag": "🇨🇷", "tax_year": "1 January to 31 December", "tax_basis": "territorial", "summary": "Costa Rica's Income Tax Law taxes income of Costa Rican source, defined as income generated exclusively within national territory regardless of the nationality, domicile or residence of the parties. Since Law 10381 of 14 September 2023, certain foreign-source passive income (dividends, interest, royalties, capital gains and real estate or other capital income) is taxed by exception, but only when earned by an entity in a multinational group that is not a qualified entity with adequate economic substance in Costa Rica.", "residence_rules": [ { "id": "CR-RES-01", "title": "Domiciled status of individuals set at the close of each fiscal period", "kind": "registration", "text": "The tax on profits applies to individuals, legal entities and collective bodies domiciled in Costa Rica that carry on profit-making activities of Costa Rican source. The law says whether an individual is domiciled or not is established at the close of each fiscal period, with special cases set by regulation. The detailed domicile criteria for individuals are in the regulation and were not verified for this record.", "threshold_days": null, "window": "tax-year", "day_method": null, "source_title": "Ley 7092, Ley del Impuesto sobre la Renta, artículos 1 y 2 (versión vigente, SCIJ/Sinalevi)", "source_url": "https://sinalevi.go.cr/ResultadosNormativa/Informacion?param1=10969¶m2=148972¶m3=1", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "CR-RES-02", "title": "Permanent establishment of non-domiciled persons: more than 183 days in any twelve months", "kind": "day-count", "text": "The law treats a non-domiciled person as having a permanent establishment where it has a fixed place of business in Costa Rica, and also where construction or installation projects, or services by its employees or contracted staff, continue for more than 183 days in any twelve-month period beginning or ending in the fiscal year. Periods of associated companies can be added together in some cases. This is a business-presence rule, not a test of individual residence.", "threshold_days": 183, "window": "rolling-12-months", "day_method": null, "source_title": "Ley 7092, Ley del Impuesto sobre la Renta, artículo 2 (reformado por la Ley 10381 de 2023)", "source_url": "https://sinalevi.go.cr/ResultadosNormativa/Informacion?param1=10969¶m2=148972¶m3=1", "source_type": "primary-law", "effective": "Law 10381 of 14 September 2023", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": null, "reporting": [], "social_security": null, "living_base": "Foreign nationals live in Costa Rica under residence categories set by the migration law and administered by the Dirección General de Migración y Extranjería; the categories were not verified from an official page for this record. Residence status does not change the territorial scope of the income tax, and the domiciled status for tax purposes is set at the close of each fiscal period.", "citizenship": "The Constitution (article 14) allows naturalization for nationals of other Central American countries, Spaniards and Ibero-Americans by birth after five years of official residence, for other foreign nationals after at least seven years, and for people married to a Costa Rican for two years who have lived in the country for the same period, subject to the requirements of article 15 and the law. Article 16 says Costa Rican nationality is not lost and cannot be renounced.", "questions": [ "Which of my income items would count as Costa Rican source under article 1, and which as foreign source?", "How does the regulation decide whether I am domiciled in Costa Rica at the close of the fiscal period?", "If I hold assets through a company that belongs to a multinational group, could the Law 10381 exception for foreign passive income apply?", "What would a qualified entity need to show to have adequate economic substance in Costa Rica?", "Have any reforms after Law 10381 changed how foreign-source passive income is treated, and from when?", "Could my work or my company's projects in Costa Rica create a permanent establishment under the 183-day thresholds?", "Which residence category and naturalization period would apply to my situation?" ], "authorities": [ { "title": "Ministerio de Hacienda – Dirección General de Tributación", "url": "https://www.hacienda.go.cr" }, { "title": "Dirección General de Migración y Extranjería", "url": "https://www.migracion.go.cr" } ], "sources": [ { "title": "Ley 7092, Ley del Impuesto sobre la Renta (versión vigente), Sistema Costarricense de Información Jurídica", "url": "https://sinalevi.go.cr/ResultadosNormativa/Informacion?param1=10969¶m2=148972¶m3=1", "type": "primary-law" }, { "title": "Constitución Política de la República de Costa Rica (versión vigente), artículos 14 a 16", "url": "https://sinalevi.go.cr/ResultadosNormativa/Informacion?param1=871¶m2=147492¶m3=1", "type": "primary-law" }, { "title": "Ley 7092, Ley del Impuesto sobre la Renta (earlier text, Ministerio de Educación Pública copy), for comparison of article 1 before Law 10381", "url": "https://www.mep.go.cr/sites/default/files/2024-12/3LeyImpestoRentaN%C2%B07092.pdf", "type": "primary-law" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "cy", "name": "Cyprus", "slug": "cyprus", "region": "Europe", "flag": "🇨🇾", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "residence", "summary": "Cyprus treats an individual as tax resident under either a 183-day rule or a 60-day rule with extra conditions, and residents are taxed on income from Cyprus and abroad. A separate domicile test decides who pays Special Defence Contribution on interest, dividends and, up to the 2025 tax year, rent, so residence and domicile are two different questions.", "residence_rules": [ { "id": "CY-RES-01", "title": "183-day rule", "kind": "day-count", "text": "An individual who stays in Cyprus for one or more periods exceeding 183 days in total during a tax year is treated as resident. The day of arrival counts as a day in Cyprus and the day of departure counts as a day outside Cyprus. Arrival and departure on the same day counts as a day in Cyprus, while departure and return on the same day counts as a day outside Cyprus.", "threshold_days": 183, "window": "tax-year", "day_method": "official-guidance", "source_title": "Tax Residency/Domicility - Tax Department - Gov.cy", "source_url": "https://www.gov.cy/mof-tax/en/documents/tax-residency-domicility/", "source_type": "official-guidance", "effective": "Income Tax Law N. 118(I)/2002, Article 2", "checked": "2026-11-08" }, { "id": "CY-RES-02", "title": "60-day rule", "kind": "day-count", "text": "An individual who does not reach 183 days may still be resident if all of these conditions are met in the tax year: at least 60 days in Cyprus, not more than 183 days in another country, carrying on a business or being employed or holding an office in Cyprus, and keeping a permanent residence in Cyprus that they own or rent. If the business or employment in Cyprus ends during the year, the person stops being treated as resident for that year under this rule. Earlier official material also listed a condition of not being tax resident in another state, so check which wording applies to the year in question.", "threshold_days": 60, "window": "tax-year", "day_method": "official-guidance", "source_title": "Tax Residency/Domicility - Tax Department - Gov.cy", "source_url": "https://www.gov.cy/mof-tax/en/documents/tax-residency-domicility/", "source_type": "official-guidance", "effective": "Conditions as listed on the Tax Department page checked 2026-11-08", "checked": "2026-11-08" }, { "id": "CY-RES-03", "title": "Domicile for Special Defence Contribution", "kind": "ties", "text": "Special Defence Contribution applies to individuals who are both Cyprus tax resident and domiciled in Cyprus. Domicile generally follows the domicile of origin, with exceptions for people who acquired a domicile of choice abroad and were not Cyprus tax resident for at least 20 consecutive years before the tax year. Anyone who has been Cyprus tax resident for at least 17 of the 20 years before the tax year is deemed domiciled, and keeps that status until they complete 20 years in which they are not Cyprus tax resident.", "threshold_days": null, "window": "multi-year", "day_method": null, "source_title": "Tax Residency/Domicility - Tax Department - Gov.cy", "source_url": "https://www.gov.cy/mof-tax/en/documents/tax-residency-domicility/", "source_type": "official-guidance", "effective": "Special Defence Contribution Law N. 117(I)/2002, as amended", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Under the 60-day rule (CY-RES-02), a person whose business or employment in Cyprus ends during the year stops being treated as resident for that year under that rule. The sources checked do not set out a general split-year or departure rule; check the current official guidance.", "reporting": [ { "title": "Form T.F.38: exemption as non-domiciled", "text": "An individual who considers that they do not have a domicile in Cyprus may apply for exemption from Special Defence Contribution by completing Form T.F.38.", "source_url": "https://www.gov.cy/mof-tax/en/documents/tax-residency-domicility/" }, { "title": "Form TD 631: alternative method for Special Defence Contribution", "text": "An individual without a Cyprus domicile of origin who is deemed domiciled under the 17-of-20-years rule may elect the alternative method, which extends the exemption for up to two further five-year periods on payment of EUR 250,000 for each period, under Article 3D of the Special Defence Contribution Law and circular 02/2026.", "source_url": "https://www.gov.cy/mof-tax/en/documents/tax-residency-domicility/" } ], "social_security": "Cyprus applies the EU rules on social security coordination: a person is generally covered by one country's system at a time, and a PD A1 form can show continued home-country cover during a temporary posting. EURES notes that employers pay social insurance and general healthcare contributions for employees; check current rates with the Cyprus social insurance authorities.", "living_base": "EU citizens can stay in Cyprus for up to three months without registering, and EURES says they must register with the Civil Registry and Migration Department within four months of arrival for longer stays; after five years of continuous lawful residence they acquire the right of permanent residence. Non-EU nationals generally need a visa or residence permit under national rules. Registration or a permit does not by itself decide tax residence; the 183-day and 60-day rules do.", "citizenship": "Cypriot citizenship is acquired mainly by descent or by naturalization after a period of lawful residence, with other routes set by national law. This record has not verified the current residence period or the position on dual citizenship; check the Ministry of Interior's current guidance.", "questions": [ "Which test applies to me in each tax year, the 183-day rule or the 60-day rule, and what records show my days in and out of Cyprus?", "Does my business, employment or office in Cyprus meet the 60-day rule condition, and what happens if it ends during the year?", "Does my owned or rented home in Cyprus count as a permanent residence for the 60-day rule?", "Am I domiciled or deemed domiciled in Cyprus for Special Defence Contribution, and does Form T.F.38 or Form TD 631 apply to my situation?", "Does another country also treat me as tax resident, and how does the tax treaty between that country and Cyprus decide my residence?", "What social insurance and healthcare contributions apply to my work or business in Cyprus?", "What evidence does the Tax Department ask for before issuing a tax residency certificate?" ], "authorities": [ { "title": "Cyprus Tax Department", "url": "https://www.gov.cy/mof-tax/en/" }, { "title": "Ministry of Interior (Civil Registry and Migration Department)", "url": "https://www.gov.cy/moi/en/" } ], "sources": [ { "title": "Tax Residency/Domicility - Tax Department - Gov.cy", "url": "https://www.gov.cy/mof-tax/en/documents/tax-residency-domicility/", "type": "official-guidance" }, { "title": "Cyprus - Information on Residency for tax purposes (OECD AEOI portal, 28 April 2023)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Cyprus-Tax-Residency.pdf", "type": "official-guidance" }, { "title": "Living and working conditions: Cyprus - EURES", "url": "https://eures.europa.eu/living-and-working/living-and-working-conditions-europe/living-and-working-conditions-cyprus_en", "type": "official-guidance" }, { "title": "Income taxes abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/taxes/income-taxes-abroad/index_en.htm", "type": "official-guidance" }, { "title": "Social security cover when you live or work in another EU country - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights when living abroad in the EU - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "cz", "name": "Czechia", "slug": "czechia", "region": "Europe", "flag": "🇨🇿", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "residence", "summary": "Czechia treats an individual as tax resident if they have a domicile there, meaning a permanent dwelling held in circumstances that show an intent to stay permanently, or if they habitually stay there for at least 183 days in a calendar year. The two tests apply independently, and meeting the day test makes a person resident for the whole calendar year.", "residence_rules": [ { "id": "CZ-RES-01", "title": "Domicile (bydliště) in Czechia", "kind": "ties", "text": "Under § 2(4) of the Income Taxes Act (No. 586/1992), domicile is a permanent dwelling held in circumstances showing an intent to stay there permanently, judged by personal and family circumstances or economic activity. The dwelling can be owned or rented and must be available whenever the person needs it; in some cases a hotel or short-term rental can count. Residence under this test starts and ends on a specific day, so a person can be resident for only part of a calendar year.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Informace k určování daňové rezidence fyzických osob (Generální finanční ředitelství, č. j. 39105/26/7100-20113-010370)", "source_url": "https://financnisprava.gov.cz/assets/cs/prilohy/ms-prime-dane/GFR_met_informace_danova_rezidence_2026_FS.pdf", "source_type": "official-guidance", "effective": "Income Taxes Act No. 586/1992, § 2(2) and § 2(4)", "checked": "2026-11-08" }, { "id": "CZ-RES-02", "title": "Habitual stay of at least 183 days in a calendar year", "kind": "day-count", "text": "A person habitually stays in Czechia if they are present there for at least 183 days in the calendar year, and every commenced day counts. Meeting this test makes the person resident for the whole calendar year, from 1 January. The date of a residence permit and the country of health or social insurance do not decide the count; presence can be shown with bank statements, personal records and travel or accommodation documents.", "threshold_days": 183, "window": "calendar-year", "day_method": "any-part", "source_title": "Informace k určování daňové rezidence fyzických osob (Generální finanční ředitelství, č. j. 39105/26/7100-20113-010370)", "source_url": "https://financnisprava.gov.cz/assets/cs/prilohy/ms-prime-dane/GFR_met_informace_danova_rezidence_2026_FS.pdf", "source_type": "official-guidance", "effective": "Income Taxes Act No. 586/1992, § 2(4)", "checked": "2026-11-08" }, { "id": "CZ-RES-03", "title": "Stays only for study or medical treatment", "kind": "ties", "text": "Under § 2(3) of the Income Taxes Act, people who stay in Czechia only to study or receive medical treatment are not treated as resident, even if they have a domicile or habitually stay there. Guidance notes that this changes if the person starts a business or employment in Czechia, because the stay is then no longer only for study or treatment.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Informace k určování daňové rezidence fyzických osob (Generální finanční ředitelství, č. j. 39105/26/7100-20113-010370)", "source_url": "https://financnisprava.gov.cz/assets/cs/prilohy/ms-prime-dane/GFR_met_informace_danova_rezidence_2026_FS.pdf", "source_type": "official-guidance", "effective": "Income Taxes Act No. 586/1992, § 2(3)", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Under CZ-RES-01, residence starts and ends on the day domicile arises or ends, so a person can be resident for part of the calendar year and taxed on worldwide income only for that part. Under CZ-RES-02, residence covers the whole calendar year. Where a tax treaty applies, it can also split residence within a year.", "reporting": [], "social_security": "Czechia applies the EU rules on social security coordination: a person is generally covered by one country's system at a time, and a PD A1 form can show continued home-country cover during a temporary posting. Check national contribution rules with the Czech social security authorities.", "living_base": "EU citizens can stay in Czechia for up to three months without registering and may need to register for longer stays; after five years of continuous lawful residence they acquire the right of permanent residence. Non-EU nationals generally need a long-stay visa or residence permit, handled by the Ministry of the Interior. Guidance states that the date a residence permit was granted does not decide the 183-day count; the tests above decide tax residence.", "citizenship": "Czech citizenship is acquired mainly by descent or by naturalization after a period of lawful residence, with other routes set by national law. This record has not verified the current residence period or the position on dual citizenship; check the Ministry of the Interior's current guidance.", "questions": [ "Do I have a permanent dwelling in Czechia in circumstances that show an intent to stay there permanently, and from which date?", "How many days, counting every commenced day, have I been present in Czechia in each calendar year?", "If I meet the 183-day test, which income becomes taxable in Czechia for the whole year?", "Does another country also treat me as tax resident, and how does the tax treaty decide my residence and any split within the year?", "Does the exception for stays only for study or medical treatment apply to me?", "What certificate of tax residence from another country will the Czech tax office or my payer ask for?" ], "authorities": [ { "title": "Financial Administration of the Czech Republic", "url": "https://financnisprava.gov.cz/en/" }, { "title": "Ministry of the Interior: Information Portal for Foreigners", "url": "https://ipc.gov.cz/en/" } ], "sources": [ { "title": "Informace k určování daňové rezidence fyzických osob (Generální finanční ředitelství, č. j. 39105/26/7100-20113-010370)", "url": "https://financnisprava.gov.cz/assets/cs/prilohy/ms-prime-dane/GFR_met_informace_danova_rezidence_2026_FS.pdf", "type": "official-guidance" }, { "title": "Income taxes abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/taxes/income-taxes-abroad/index_en.htm", "type": "official-guidance" }, { "title": "Social security cover when you live or work in another EU country - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights when living abroad in the EU - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "de", "name": "Germany", "slug": "germany", "region": "Europe", "flag": "🇩🇪", "tax_year": "1 January to 31 December", "tax_basis": "residence", "summary": "Germany applies unlimited income tax liability to individuals who have a residence (Wohnsitz, §8 AO) or habitual abode (gewöhnlicher Aufenthalt, §9 AO) in Germany, under §1(1) EStG. A dwelling kept and used under circumstances that suggest continued use can be enough on its own, so a day count is not the only test; a continuous stay of more than six months is always treated as a habitual abode from its start.", "residence_rules": [ { "id": "DE-RES-01", "title": "Residence (Wohnsitz) under §8 AO", "kind": "ties", "text": "A person has a residence where they hold a dwelling under circumstances suggesting they will keep and use it. The test looks at the dwelling and how it is kept, not at a number of days, so it can apply even with short stays.", "threshold_days": null, "window": null, "day_method": null, "source_title": "§ 8 AO Wohnsitz", "source_url": "https://www.gesetze-im-internet.de/ao_1977/__8.html", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "DE-RES-02", "title": "Habitual abode (gewöhnlicher Aufenthalt) under §9 AO", "kind": "day-count", "text": "A person has a habitual abode where they stay under circumstances showing they are not there only temporarily. A continuous stay in Germany of more than six months is always treated as a habitual abode from its start, and brief interruptions are disregarded. The six-month rule does not apply to stays solely for visits, recreation, medical cure or similar private purposes lasting no longer than one year. The law states months, not a day number.", "threshold_days": null, "window": null, "day_method": null, "source_title": "§ 9 AO Gewöhnlicher Aufenthalt", "source_url": "https://www.gesetze-im-internet.de/ao_1977/__9.html", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "DE-RES-03", "title": "Extended unlimited liability for German public employees abroad", "kind": "citizenship", "text": "German citizens without a residence or habitual abode in Germany are still treated as having unlimited liability if they work for a German public-law employer and are paid from a German public fund; household family members can be covered under similar conditions. This applies only to that group, not to German citizens in general.", "threshold_days": null, "window": null, "day_method": null, "source_title": "§ 1 EStG Steuerpflicht", "source_url": "https://www.gesetze-im-internet.de/estg/__1.html", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "On giving up residence or habitual abode (DE-RES-01, DE-RES-02), §6 AStG treats shareholdings covered by §17 EStG as sold at fair value if the person had unlimited liability for at least seven years in total within the twelve years before. On application the tax can be paid in seven equal annual instalments, generally with security, and the claim lapses if unlimited liability resumes within seven years and the other conditions are met.", "reporting": [ { "title": "Exit tax follow-up under §6(5) AStG", "text": "Relevant events must be reported electronically within one month, and each year by 31 July the person must confirm their current address and that they still hold the shares.", "source_url": "https://www.gesetze-im-internet.de/astg/__6.html" }, { "title": "Application for unlimited liability under §1(3) EStG", "text": "People without a German residence or habitual abode who have German-source income can apply to be treated as having unlimited liability, mainly where at least 90 percent of their income is subject to German income tax.", "source_url": "https://www.gesetze-im-internet.de/estg/__1.html" } ], "social_security": "Within the EU, a person is covered by one country's social security system at a time, and which one depends on work situation and residence, not nationality. Check the EU coordination rules and any bilateral agreement for work involving non-EU countries.", "living_base": "EU citizens can move to Germany under EU free movement rules, with permanent residence after a continuous 5-year period of legal residence. Others generally need a visa and a residence title for purposes such as work, study or family. A residence title does not decide tax liability, which follows §8 and §9 AO.", "citizenship": "Under §10(1) StAG, naturalisation by entitlement requires five years of lawful habitual residence in Germany, among other conditions; the former three-year route in §10(3) has been repealed. The conditions in §10 do not include giving up a previous nationality, and the former rule in §25 StAG on losing German citizenship by acquiring a foreign one has been repealed.", "questions": [ "Could a dwelling I keep in Germany count as a residence under §8 AO, even if I spend little time there?", "Would my stays in Germany form a continuous stay of more than six months under §9 AO?", "If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?", "Could §6 AStG apply to my shareholdings if I give up my German residence, and would instalments or the return rule apply?", "Would an application under §1(3) EStG be relevant to my German-source income?", "Which social security system covers my work pattern under EU rules or a bilateral agreement?" ], "authorities": [ { "title": "Bundeszentralamt für Steuern (BZSt)", "url": "https://www.bzst.de" }, { "title": "Bundesministerium der Finanzen", "url": "https://www.bundesfinanzministerium.de" }, { "title": "Bundesamt für Migration und Flüchtlinge (BAMF)", "url": "https://www.bamf.de" } ], "sources": [ { "title": "§ 8 AO Wohnsitz", "url": "https://www.gesetze-im-internet.de/ao_1977/__8.html", "type": "primary-law" }, { "title": "§ 9 AO Gewöhnlicher Aufenthalt", "url": "https://www.gesetze-im-internet.de/ao_1977/__9.html", "type": "primary-law" }, { "title": "§ 1 EStG Steuerpflicht", "url": "https://www.gesetze-im-internet.de/estg/__1.html", "type": "primary-law" }, { "title": "§ 6 AStG Besteuerung des Vermögenszuwachses", "url": "https://www.gesetze-im-internet.de/astg/__6.html", "type": "primary-law" }, { "title": "§ 10 StAG", "url": "https://www.gesetze-im-internet.de/stag/__10.html", "type": "primary-law" }, { "title": "§ 25 StAG (weggefallen)", "url": "https://www.gesetze-im-internet.de/stag/__25.html", "type": "primary-law" }, { "title": "Social security cover abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "ee", "name": "Estonia", "slug": "estonia", "region": "Europe", "flag": "🇪🇪", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "residence", "summary": "Estonia treats an individual as tax resident if their place of residence is in Estonia or they stay in Estonia for at least 183 days over 12 consecutive calendar months. Owning property in Estonia does not by itself create residence, and e-Residency is a digital identity that does not change a person's tax residence.", "residence_rules": [ { "id": "EE-RES-01", "title": "Place of residence in Estonia", "kind": "ties", "text": "Under § 6(1) of the Income Tax Act, a person whose place of residence is in Estonia is resident. The place of residence is where the person permanently or primarily lives. Possessing property in Estonia, including real estate, does not by itself make a person resident. Estonian diplomats in foreign service are also resident.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Determining residency - Estonian Tax and Customs Board", "source_url": "https://www.emta.ee/en/private-client/foreigner-non-resident/tax-residency/determining-residency", "source_type": "official-guidance", "effective": "Income Tax Act § 6(1)", "checked": "2026-11-08" }, { "id": "EE-RES-02", "title": "183 days over 12 consecutive calendar months", "kind": "day-count", "text": "A person who stays in Estonia for at least 183 days over a period of 12 consecutive calendar months is resident, and is considered resident from the date of arrival. Only days present in Estonia count. Days spent in Estonia partially, including days of arrival and departure, count as days in Estonia, while full days abroad do not.", "threshold_days": 183, "window": "rolling-12-months", "day_method": "any-part", "source_title": "Determining residency - Estonian Tax and Customs Board", "source_url": "https://www.emta.ee/en/private-client/foreigner-non-resident/tax-residency/determining-residency", "source_type": "official-guidance", "effective": "Income Tax Act § 6(1)", "checked": "2026-11-08" }, { "id": "EE-RES-03", "title": "Tax treaty residence takes priority", "kind": "ties", "text": "If residence under a tax treaty differs from residence under the Income Tax Act, the treaty provisions apply. A person treated as resident of the other country under a treaty is treated as not resident under the Estonian Income Tax Act. A tax residency certificate from the other country is needed to apply treaty relief.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Estonia - Information on residency for tax purposes (OECD AEOI portal)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Estonia-Tax-Residency.pdf", "source_type": "official-guidance", "effective": "Income Tax Act § 6", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "A person who meets EE-RES-02 is resident from the date of arrival. A resident who settles in another country, keeps no place of residence in Estonia and stays fewer than 183 days is treated as not resident from the day after leaving Estonia (EE-RES-01 and EE-RES-02).", "reporting": [ { "title": "Form R: application for determination of residency", "text": "A person who arrives in Estonia submits an application for determination of residency (form R) to the Tax and Customs Board. A person must also notify the Board of circumstances that change their residency for tax purposes.", "source_url": "https://www.emta.ee/en/private-client/foreigner-non-resident/tax-residency/determining-residency" } ], "social_security": "Estonia applies the EU rules on social security coordination: a person is generally covered by one country's system at a time, and a PD A1 form can show continued home-country cover during a temporary posting. Check national contribution rules with the Estonian Tax and Customs Board.", "living_base": "EU citizens can stay in Estonia for up to three months without registering and may need to register for longer stays; after five years of continuous lawful residence they acquire the right of permanent residence. Non-EU nationals generally need a visa or residence permit, handled by the Police and Border Guard Board. e-Residency gives no right of entry or residence and does not change individual tax residence, and a company run by an e-resident may create a taxable presence in the country where that person lives.", "citizenship": "Estonian citizenship is acquired mainly by descent or by naturalization after a period of lawful residence, with other routes set by national law. e-Residency does not give any rights of citizenship. This record has not verified the current residence period or the position on dual citizenship; check the Police and Border Guard Board's current guidance.", "questions": [ "Where is my place of residence for Estonian purposes, meaning where I permanently or primarily live?", "How many days have I spent in Estonia in each 12-month period, counting partial days, and from which date would residence start?", "Have I filed form R, and do I need to notify the Tax and Customs Board of a change in my circumstances?", "Does another country also treat me as tax resident, and how does the tax treaty decide my residence?", "If I run an Estonian company as an e-resident, could it have a permanent establishment in the country where I live?", "What happens to my Estonian residence status in the year I leave Estonia?" ], "authorities": [ { "title": "Estonian Tax and Customs Board (EMTA)", "url": "https://www.emta.ee/en" }, { "title": "Police and Border Guard Board", "url": "https://www.politsei.ee/en" }, { "title": "e-Residency programme", "url": "https://www.e-resident.gov.ee/" } ], "sources": [ { "title": "Determining residency - Estonian Tax and Customs Board", "url": "https://www.emta.ee/en/private-client/foreigner-non-resident/tax-residency/determining-residency", "type": "official-guidance" }, { "title": "Estonia - Information on residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Estonia-Tax-Residency.pdf", "type": "official-guidance" }, { "title": "Dos and don'ts of e-Residency", "url": "https://www.e-resident.gov.ee/blog/posts/dos-and-donts/", "type": "official-guidance" }, { "title": "Social security cover when you live or work in another EU country - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights when living abroad in the EU - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "es", "name": "Spain", "slug": "spain", "region": "Europe", "flag": "🇪🇸", "tax_year": "1 January to 31 December", "tax_basis": "residence", "summary": "Spain treats a person as habitually resident for a whole calendar year if they stay in Spain more than 183 days in that year, counting sporadic absences unless tax residence in another country is proven, or if the main base of their activities or economic interests is in Spain; residence is also presumed if a spouse and dependent minor children live in Spain. A special regime under article 93 of the IRPF Law lets some people who move to Spain for work opt to be taxed under non-resident income tax rules, with specific features, for the year of the move and the five following years.", "residence_rules": [ { "id": "ES-RES-01", "title": "More than 183 days in the calendar year", "kind": "day-count", "text": "A person is habitually resident if they stay in Spain more than 183 days during the calendar year. Sporadic absences are counted as days in Spain unless the person proves tax residence in another country, and for listed tax havens the tax authority may require proof of presence there for 183 days in the year.", "threshold_days": 183, "window": "calendar-year", "day_method": "official-guidance", "source_title": "Residencia habitual en territorio español (Manual práctico IRPF 2025)", "source_url": "https://sede.agenciatributaria.gob.es/Sede/ayuda/manuales-videos-folletos/manuales-practicos/irpf-2025/c02-irpf-cuestiones-generales/sujecion-irpf-aspectos-personales/residencia-habitual-territorio-espanol.html", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "ES-RES-02", "title": "Main base of activities or economic interests", "kind": "ties", "text": "A person is also habitually resident if the main base of their activities or economic interests is in Spain, directly or indirectly. This test applies even when the day count is not met.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "Residencia habitual en territorio español (Manual práctico IRPF 2025)", "source_url": "https://sede.agenciatributaria.gob.es/Sede/ayuda/manuales-videos-folletos/manuales-practicos/irpf-2025/c02-irpf-cuestiones-generales/sujecion-irpf-aspectos-personales/residencia-habitual-territorio-espanol.html", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "ES-RES-03", "title": "Family presumption", "kind": "presumption", "text": "Residence is presumed, unless proven otherwise, when the spouse who is not legally separated and the dependent minor children habitually reside in Spain. It is a rebuttable presumption, not a day count.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "Residencia habitual en territorio español (Manual práctico IRPF 2025)", "source_url": "https://sede.agenciatributaria.gob.es/Sede/ayuda/manuales-videos-folletos/manuales-practicos/irpf-2025/c02-irpf-cuestiones-generales/sujecion-irpf-aspectos-personales/residencia-habitual-territorio-espanol.html", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "ES-RES-04", "title": "Spanish nationals moving to a non-cooperative jurisdiction", "kind": "citizenship", "text": "Spanish nationals who prove a new residence in a tax haven remain IRPF taxpayers in the tax period of the change and in the four following tax periods. Since 11 July 2021, references to tax havens mean non-cooperative jurisdictions.", "threshold_days": null, "window": "multi-year", "day_method": null, "source_title": "Persona física residente en España", "source_url": "https://sede.agenciatributaria.gob.es/Sede/no-residentes/residencia-personas-fisicas-juridicas/persona-fisica-residente-espana.html", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Spain sets residence for the whole calendar year, and a change of residence does not split the tax period (ES-RES-01 to ES-RES-03). On departure, article 95 bis of the IRPF Law can tax unrealized gains on shares for people resident in at least 10 of the 15 prior tax periods, where the shares exceed €4,000,000 in total market value, or where a stake above 25% in one entity exceeds €1,000,000; a deferral option exists for moves to EU or EEA states with tax information exchange.", "reporting": [ { "title": "Special regime for workers moving to Spain (article 93 IRPF Law)", "text": "People who were not resident in Spain in the five tax periods before the move can opt for the regime with form 149, which is also used to renounce it or report exclusion; the annual return is form 151. Employment income obtained during the regime is treated as obtained in Spain.", "source_url": "https://sede.agenciatributaria.gob.es/Sede/ayuda/manuales-videos-folletos/manuales-practicos/manual-tributacion-no-residentes/regimenes-opcionales/regimen-especial-impatriados.html" }, { "title": "Form 720: assets and rights located abroad", "text": "An information return on foreign bank accounts, securities and real estate held by Spanish tax residents. The tax authority applies its €50,000 limit to each category separately.", "source_url": "https://sede.agenciatributaria.gob.es/Sede/procedimientoini/GI34.shtml" }, { "title": "Exit tax return on unrealized gains", "text": "Gains under article 95 bis are included in the taxable base of the last tax period that must be declared, through a supplementary self-assessment.", "source_url": "https://sede.agenciatributaria.gob.es/Sede/ayuda/manuales-videos-folletos/manuales-practicos/irpf-2024/c11-ganancias-perdidas-patrimoniales/regimen-especial-ganancias-patrimoniales-cambio-residencia/introduccion-ambito-aplicacion.html" } ], "social_security": "Within the EU, a person is covered by one country's social security system at a time, and which one depends on work situation and residence, not nationality. Check the EU coordination rules and any bilateral agreement for work involving non-EU countries.", "living_base": "EU citizens can move to Spain under EU free movement rules, with permanent residence after a continuous 5-year period of legal residence. Others generally need a visa or residence authorization under Spanish immigration law. A residence authorization does not decide tax residence, which follows article 9 of the IRPF Law.", "citizenship": "Under article 22 of the Civil Code, nationality by residence generally requires 10 years of legal, continuous residence immediately before the application, five years for refugees, two years for nationals of origin of Ibero-American countries, Andorra, the Philippines, Equatorial Guinea or Portugal and for Sephardic Jews, and one year in listed cases such as one year of marriage to a Spanish national. Article 23 requires the applicant to declare renunciation of their previous nationality, except nationals of the countries listed in article 24.1 and Sephardic Jews originating from Spain.", "questions": [ "How are my days in Spain counted, and would my absences be treated as sporadic?", "Where is the main base of my activities or economic interests for Spanish purposes?", "Does the family presumption apply to me, and what evidence could rebut it?", "Do I meet the conditions of the article 93 special regime, and what deadline applies to form 149?", "Do I need to file form 720 for any category of foreign assets?", "Could the article 95 bis exit tax apply if I leave, and is the EU or EEA deferral option relevant?", "If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?" ], "authorities": [ { "title": "Agencia Tributaria", "url": "https://sede.agenciatributaria.gob.es" }, { "title": "Ministerio de Justicia (nacionalidad)", "url": "https://www.mjusticia.gob.es" }, { "title": "Ministerio de Inclusión, Seguridad Social y Migraciones", "url": "https://www.inclusion.gob.es" } ], "sources": [ { "title": "Residencia habitual en territorio español (Manual práctico IRPF 2025)", "url": "https://sede.agenciatributaria.gob.es/Sede/ayuda/manuales-videos-folletos/manuales-practicos/irpf-2025/c02-irpf-cuestiones-generales/sujecion-irpf-aspectos-personales/residencia-habitual-territorio-espanol.html", "type": "official-guidance" }, { "title": "Persona física residente en España", "url": "https://sede.agenciatributaria.gob.es/Sede/no-residentes/residencia-personas-fisicas-juridicas/persona-fisica-residente-espana.html", "type": "official-guidance" }, { "title": "Régimen especial impatriados art. 93 Ley IRPF", "url": "https://sede.agenciatributaria.gob.es/Sede/ayuda/manuales-videos-folletos/manuales-practicos/manual-tributacion-no-residentes/regimenes-opcionales/regimen-especial-impatriados.html", "type": "official-guidance" }, { "title": "Régimen fiscal aplicable a los trabajadores desplazados a territorio español - Régimen especial", "url": "https://sede.agenciatributaria.gob.es/Sede/irpf/tengo-que-presentar-declaracion/regimen-fiscal-aplicable-trabajadores-desplazados/regimen-especial.html", "type": "official-guidance" }, { "title": "Introducción y ámbito de aplicación (ganancias patrimoniales por cambio de residencia)", "url": "https://sede.agenciatributaria.gob.es/Sede/ayuda/manuales-videos-folletos/manuales-practicos/irpf-2024/c11-ganancias-perdidas-patrimoniales/regimen-especial-ganancias-patrimoniales-cambio-residencia/introduccion-ambito-aplicacion.html", "type": "official-guidance" }, { "title": "Modelo 720. Declaración informativa sobre bienes y derechos situados en el extranjero", "url": "https://sede.agenciatributaria.gob.es/Sede/procedimientoini/GI34.shtml", "type": "official-guidance" }, { "title": "Código Civil (Real Decreto de 24 de julio de 1889), texto consolidado", "url": "https://www.boe.es/buscar/act.php?id=BOE-A-1889-4763", "type": "primary-law" }, { "title": "Social security cover abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "fr", "name": "France", "slug": "france", "region": "Europe", "flag": "🇫🇷", "tax_year": "1 January to 31 December", "tax_basis": "residence", "summary": "Under article 4 B of the General Tax Code, a person has a French tax domicile if they have their home (foyer) or principal place of stay in France, carry on a professional activity there that is not ancillary, or have the centre of their economic interests there; meeting any one criterion is enough. There is no statutory day count: tax guidance treats a stay of more than six months in a year as a general indication of principal stay but says this is not an absolute criterion, and a tax treaty can override the domestic result.", "residence_rules": [ { "id": "FR-RES-01", "title": "Home (foyer) or principal place of stay", "kind": "ties", "text": "The foyer is the place where a person normally lives, provided it is permanent; professional travel does not necessarily change it if the family keeps living there. The principal place of stay looks at physical presence. Tax guidance says people who stay in France more than six months in a year are normally treated as having their principal stay there, but the six-month rule is not an absolute criterion and the overall circumstances are considered.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "IR - Champ d'application et territorialité - Personnes imposables et domicile fiscal (BOI-IR-CHAMP-10)", "source_url": "https://bofip.impots.gouv.fr/bofip/1911-PGP.html/identifiant=BOI-IR-CHAMP-10-20160728", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "FR-RES-02", "title": "Professional activity in France", "kind": "ties", "text": "A person who carries on a professional activity in France, employed or self-employed, has a French tax domicile unless that activity is ancillary. Where a person has several activities, guidance looks first at where they spend the most actual time, and if that does not decide, at where most of their worldwide income comes from.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "Article 4 B - Code général des impôts", "source_url": "https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051202565", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "FR-RES-03", "title": "Centre of economic interests", "kind": "ties", "text": "A person also has a French tax domicile if the centre of their economic interests is in France. Guidance places it where the person made their main investments, has the seat of their affairs or manages their assets, or where they have the centre of their professional activity or earn most of their income.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "IR - Champ d'application et territorialité - Personnes imposables et domicile fiscal (BOI-IR-CHAMP-10)", "source_url": "https://bofip.impots.gouv.fr/bofip/1911-PGP.html/identifiant=BOI-IR-CHAMP-10-20160728", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "On departure, article 167 bis of the General Tax Code (exit tax) can tax unrealized gains for a person who was a French tax resident for at least six of the ten years before the transfer and holds shares, securities or rights worth at least €800,000 in total or representing at least 50% of a company's profits. Article 4 B also treats some French state agents working abroad as French tax domiciled where the host country does not tax their total income (relates to FR-RES-01 to FR-RES-03).", "reporting": [ { "title": "Foreign accounts (form 3916 / 3916 bis)", "text": "Accounts opened, used or closed abroad during the year are declared with the income tax return on form 3916 / 3916 bis, with limited exceptions set out by the tax authority.", "source_url": "https://www.impots.gouv.fr/particulier/questions/dois-je-declarer-mon-compte-paypal-ou-un-compte-bancaire-ouvert-letranger-et" }, { "title": "Exit tax declaration (form 2074-ETD)", "text": "Unrealized gains under article 167 bis are declared on form 2074-ETD for the year of transfer, followed by tracking declarations in later years.", "source_url": "https://www.impots.gouv.fr/particulier/questions/je-quitte-la-france-suis-je-concerne-par-lexit-tax" } ], "social_security": "Within the EU, a person is covered by one country's social security system at a time, and which one depends on work situation and residence, not nationality. Check the EU coordination rules and any bilateral agreement for work involving non-EU countries.", "living_base": "EU citizens can move to France under EU free movement rules, with permanent residence after a continuous 5-year period of legal residence. Others generally need a long-stay visa or residence permit. A visa or permit does not decide tax domicile, which follows article 4 B of the General Tax Code.", "citizenship": "Naturalisation by decree generally requires at least 5 years of residence in France, reduced to 2 years in listed cases such as a French higher-education diploma after 2 years of study, with no minimum for some groups such as refugees; the applicant must live in France with their main material and family ties there when the decree is signed. Service-Public states that a person can hold several nationalities and that French law does not require a foreigner who becomes French to give up their original nationality.", "questions": [ "Where is my foyer, and would my pattern of stays be treated as a principal stay in France?", "Is any professional activity I carry on in France ancillary, or is it my principal activity?", "Where is the centre of my economic interests, given my investments and sources of income?", "If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?", "Could the exit tax under article 167 bis apply to my holdings if I leave, and what payment deferral rules apply?", "Which foreign accounts do I need to declare on form 3916 / 3916 bis?" ], "authorities": [ { "title": "Direction générale des Finances publiques (impots.gouv.fr)", "url": "https://www.impots.gouv.fr" }, { "title": "Service-Public.fr", "url": "https://www.service-public.gouv.fr" }, { "title": "France-Visas", "url": "https://france-visas.gouv.fr" } ], "sources": [ { "title": "Article 4 B - Code général des impôts", "url": "https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051202565", "type": "primary-law" }, { "title": "IR - Champ d'application et territorialité - Personnes imposables et domicile fiscal (BOI-IR-CHAMP-10)", "url": "https://bofip.impots.gouv.fr/bofip/1911-PGP.html/identifiant=BOI-IR-CHAMP-10-20160728", "type": "official-guidance" }, { "title": "Je quitte la France, suis-je concerné par l'Exit Tax ?", "url": "https://www.impots.gouv.fr/particulier/questions/je-quitte-la-france-suis-je-concerne-par-lexit-tax", "type": "official-guidance" }, { "title": "Dois-je déclarer mon compte Paypal ou un compte bancaire ouvert à l'étranger ? Et si oui, comment ?", "url": "https://www.impots.gouv.fr/particulier/questions/dois-je-declarer-mon-compte-paypal-ou-un-compte-bancaire-ouvert-letranger-et", "type": "official-guidance" }, { "title": "Naturalisation française par décret", "url": "https://www.service-public.gouv.fr/particuliers/vosdroits/F2213", "type": "official-guidance" }, { "title": "Can we have several nationalities in France?", "url": "https://www.service-public.gouv.fr/particuliers/vosdroits/F334?lang=en", "type": "official-guidance" }, { "title": "Social security cover abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "gb", "name": "United Kingdom", "slug": "united-kingdom", "region": "Europe", "flag": "🇬🇧", "tax_year": "6 April to 5 April", "tax_basis": "residence", "summary": "The UK decides tax residence for each tax year with the Statutory Residence Test, which combines automatic overseas tests, automatic UK tests and a sufficient ties test, counting days present at midnight. From 6 April 2025 the remittance basis was abolished and UK residents are taxed on the arising basis, while a person in one of their first 4 years of UK residence after at least 10 consecutive tax years of non-UK residence can claim the 4-year foreign income and gains (FIG) regime.", "residence_rules": [ { "id": "GB-RES-01", "title": "Statutory Residence Test: automatic overseas tests", "kind": "day-count", "text": "These tests are checked first. A person who was UK resident in one or more of the 3 previous tax years meets the first test with fewer than 16 days in the UK; a person who was UK resident in none of those years meets the second test with fewer than 46 days. A third test covers full-time work overseas with fewer than 91 days in the UK and UK work of more than 3 hours on fewer than 31 days. Meeting one of these tests settles the year as not UK resident under the SRT.", "threshold_days": null, "window": "tax-year", "day_method": "midnight", "source_title": "RDR3: Statutory Residence Test (SRT) notes", "source_url": "https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-test-srt-rdr3", "source_type": "official-guidance", "effective": "Tax years from 6 April 2013", "checked": "2026-11-08" }, { "id": "GB-RES-02", "title": "Statutory Residence Test: automatic UK tests", "kind": "day-count", "text": "If no automatic overseas test is met, a person is UK resident if they spend 183 days or more in the UK in the tax year. Two other automatic UK tests look at having a UK home (with conditions on a 91-day period and at least 30 days of presence there) and at full-time work in the UK over a 365-day period. Days are counted when the person is in the UK at the end of the day (midnight), subject to the deeming rule, transit days and exceptional circumstances.", "threshold_days": 183, "window": "tax-year", "day_method": "midnight", "source_title": "RFIG20710 - Statutory Residence Test (SRT): Days spent in the UK: Meaning of a day spent in the UK", "source_url": "https://www.gov.uk/hmrc-internal-manuals/residence-and-fig-regime-manual/rfig20710", "source_type": "official-guidance", "effective": "Tax years from 6 April 2013", "checked": "2026-11-08" }, { "id": "GB-RES-03", "title": "Statutory Residence Test: sufficient ties test", "kind": "ties", "text": "If no automatic test decides the year, residence depends on UK days combined with UK ties: family, accommodation, work and 90-day ties, plus a country tie for people who were UK resident in one of the 3 previous years. The more ties a person has, the fewer UK days it takes to be resident. HMRC sets out the day bands and tie counts in two tables, one for people previously UK resident and one for people who were not.", "threshold_days": null, "window": "tax-year", "day_method": "midnight", "source_title": "RDR3: Statutory Residence Test (SRT) notes", "source_url": "https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-test-srt-rdr3", "source_type": "official-guidance", "effective": "Tax years from 6 April 2013", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "A tax year in which a person is UK resident can be split into a UK part and an overseas part. HMRC lists split year cases 1 to 3 for actual or deemed departures and cases 4 to 8 for actual or deemed arrivals, with priority rules where more than one case applies (relates to GB-RES-01 to GB-RES-03).", "reporting": [ { "title": "FIG regime claim", "text": "FIG relief must be claimed for each tax year it is wanted, for up to 4 consecutive tax years from the year of arrival. HMRC states that a claim removes the personal allowance and the capital gains tax annual exempt amount for that year, among other reliefs and allowances.", "source_url": "https://www.gov.uk/government/publications/foreign-income-and-gains-fig-regime-self-assessment-helpsheet-hs266/hs266-foreign-income-and-gains-fig-regime-2026" }, { "title": "Remittances of income and gains from remittance basis years", "text": "HMRC states that foreign income and gains from years when the remittance basis was claimed remain taxable in the year they are brought to the UK, and that this continues for previous remittance basis users after 6 April 2025.", "source_url": "https://www.gov.uk/guidance/remittance-basis-changes" } ], "social_security": "National Insurance usually follows the country where a person works. For work abroad, whether UK National Insurance still applies depends on the country, any social security agreement with the UK and the length and type of the work; a certificate of coverage may be needed.", "living_base": "People who are not British citizens generally need immigration permission to live in the UK, through visa families such as work, study and family routes, or settled status. Holding a visa or settlement does not decide UK tax residence; the Statutory Residence Test does.", "citizenship": "Naturalisation for people with indefinite leave to remain or settled status generally requires at least 5 years living in the UK and holding that status for 12 months, with no more than 450 days outside the UK in the 5 years and 90 days in the last 12 months. GOV.UK states that dual citizenship is allowed in the UK. Check the current rules for how long each visa route takes to reach settlement.", "questions": [ "Which Statutory Residence Test decides my status for each tax year, and how should my days and ties be counted?", "Does a split year case apply to my year of arrival or departure, and which case takes priority?", "Do I meet the condition of at least 10 consecutive tax years of non-UK residence for the FIG regime, and what allowances would a claim remove?", "How are funds from years when I used the remittance basis treated if I bring them to the UK now?", "If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?", "Which National Insurance rules or social security agreement apply to my work pattern?" ], "authorities": [ { "title": "HM Revenue and Customs (HMRC)", "url": "https://www.gov.uk/government/organisations/hm-revenue-customs" }, { "title": "UK Visas and Immigration", "url": "https://www.gov.uk/government/organisations/uk-visas-and-immigration" } ], "sources": [ { "title": "RDR3: Statutory Residence Test (SRT) notes", "url": "https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-test-srt-rdr3", "type": "official-guidance" }, { "title": "RFIG20710 - Statutory Residence Test (SRT): Days spent in the UK: Meaning of a day spent in the UK", "url": "https://www.gov.uk/hmrc-internal-manuals/residence-and-fig-regime-manual/rfig20710", "type": "official-guidance" }, { "title": "HS266 Foreign income and gains (FIG) regime (2026)", "url": "https://www.gov.uk/government/publications/foreign-income-and-gains-fig-regime-self-assessment-helpsheet-hs266/hs266-foreign-income-and-gains-fig-regime-2026", "type": "official-guidance" }, { "title": "Remittance basis changes", "url": "https://www.gov.uk/guidance/remittance-basis-changes", "type": "official-guidance" }, { "title": "National Insurance if you work abroad", "url": "https://www.gov.uk/national-insurance-if-you-go-abroad", "type": "official-guidance" }, { "title": "Apply for citizenship if you have indefinite leave to remain or 'settled status'", "url": "https://www.gov.uk/apply-citizenship-indefinite-leave-to-remain", "type": "official-guidance" }, { "title": "Dual citizenship", "url": "https://www.gov.uk/dual-citizenship", "type": "official-guidance" }, { "title": "Visas and immigration", "url": "https://www.gov.uk/browse/visas-immigration", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "ge", "name": "Georgia", "slug": "georgia", "region": "Europe", "flag": "🇬🇪", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "territorial", "summary": "Georgia treats an individual as resident for a whole tax year after 183 or more days of actual stay in any continuous 12-month period ending in that year, and its Tax Code also allows residency to be granted to high net worth individuals under a ministerial procedure. The Tax Code lists income of a resident individual that is not Georgian-source income among exempt income types, so where income is sourced matters alongside residence.", "residence_rules": [ { "id": "GE-RES-01", "title": "183 days in any continuous 12-month period", "kind": "day-count", "text": "Under Article 34 of the Tax Code, a natural person who actually stays in Georgia for 183 or more days in any continuous 12-calendar-month period ending in the tax year is resident for that entire tax year. A day counts as a day of actual stay regardless of how long the person was in Georgia that day. Time abroad specifically for treatment, leisure, business trips or education counts as time in Georgia, while time in Georgia with diplomatic or consular status, as certain international organization staff, or in transit between two foreign countries does not count. A person in the public service of Georgia abroad during the tax year is also resident.", "threshold_days": 183, "window": "rolling-12-months", "day_method": "any-part", "source_title": "Tax Code of Georgia (English translation, Legislative Herald of Georgia)", "source_url": "https://matsne.gov.ge/en/document/download/1043717/93/en/pdf", "source_type": "primary-law", "effective": "Tax Code of Georgia, Article 34; check the current consolidated version", "checked": "2026-11-08" }, { "id": "GE-RES-02", "title": "High net worth individual residency status", "kind": "registration", "text": "Article 34 allows Georgian residency to be granted to a high net worth individual under a procedure and conditions set by the Ministers of Finance and Justice, with the term defined by the Law on Securities Market. Georgia's information sheet on the OECD portal describes applying to the Revenue Service with an identity or residence-permit document and evidence that the person's property exceeds GEL 3 million or that their annual income over the last three years exceeded GEL 200,000. Check the current joint order and Revenue Service guidance for the full conditions and how often the status must be renewed.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Georgia - Information on Residency for tax purposes (OECD AEOI portal)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Georgia-Residency.pdf", "source_type": "official-guidance", "effective": "Joint Order No. 991-No. 250 of 31 December 2010 of the Ministers of Finance and Justice, as described in the OECD sheet", "checked": "2026-11-08" }, { "id": "GE-RES-03", "title": "Georgian citizens with no residence elsewhere", "kind": "citizenship", "text": "If a natural person's residence cannot be established in relation to any country, a Georgian citizen is treated as a Georgian resident if they apply to the tax authority.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Tax Code of Georgia (English translation, Legislative Herald of Georgia)", "source_url": "https://matsne.gov.ge/en/document/download/1043717/93/en/pdf", "source_type": "primary-law", "effective": "Tax Code of Georgia, Article 34", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Residence under GE-RES-01 applies to the entire tax year. Georgia's OECD information sheet adds that residence status is set for each tax period, and days used to establish residence in one period are not counted again when setting residence for the following periods.", "reporting": [], "social_security": null, "living_base": "Foreign nationals who want to live in Georgia apply for residence permits through the Public Service Development Agency, which lists work, study, family reunification, investment, short-term (property-based), IT and permanent residence permits among others. A residence permit does not by itself decide tax residence; the 183-day rule or a granted high net worth status does.", "citizenship": "Georgian citizenship is acquired by birth when a parent is a Georgian citizen, or by naturalization. The Public Service Development Agency describes a regular route after 10 consecutive years of lawful residence, with a test on language, history and legal principles and a job, property or business in Georgia, and a simplified route after 5 years for the spouse of a Georgian citizen. A Georgian citizen who acquires another citizenship keeps Georgian citizenship only with consent obtained in advance.", "questions": [ "How many days have I actually stayed in Georgia in each continuous 12-month period ending in the tax year, and how do days abroad for treatment, business or education affect the count?", "Is my income Georgian-source or foreign-source under the Tax Code, and how does Article 82 treat each part?", "What are the current conditions, documents and renewal rules for high net worth individual residency status?", "Does another country also treat me as tax resident, and how does any tax treaty with Georgia decide my residence?", "Which residence permit, if any, fits my situation, and what does it require?", "What certificate of tax residence can the Revenue Service issue for my situation, and what evidence does it ask for?" ], "authorities": [ { "title": "Revenue Service of Georgia", "url": "https://www.rs.ge/" }, { "title": "Public Service Development Agency", "url": "https://sda.gov.ge/en" }, { "title": "Legislative Herald of Georgia (Matsne)", "url": "https://matsne.gov.ge/en/document/view/1043717" } ], "sources": [ { "title": "Tax Code of Georgia (English translation, Legislative Herald of Georgia)", "url": "https://matsne.gov.ge/en/document/download/1043717/93/en/pdf", "type": "primary-law" }, { "title": "Georgia - Information on Residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Georgia-Residency.pdf", "type": "official-guidance" }, { "title": "Migration/Residence Permits - Public Service Development Agency", "url": "https://sda.gov.ge/en/products/migration-residence-permits/", "type": "official-guidance" }, { "title": "Georgian citizenship - Public Service Development Agency", "url": "https://sda.gov.ge/en/products/citizenship/", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "gr", "name": "Greece", "slug": "greece", "region": "Europe", "flag": "🇬🇷", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "residence", "summary": "Greece treats an individual as tax resident mainly on ties: a permanent or principal residence, a usual abode, or a centre of vital interests in Greece. A continuous presence of more than 183 days also makes a person resident from the first day of presence, with an exception for short private stays such as tourism or medical treatment.", "residence_rules": [ { "id": "GR-RES-01", "title": "Residence, usual abode or centre of vital interests", "kind": "ties", "text": "Under Article 4 of the Income Tax Code (Law 4172/2013), an individual is tax resident in Greece if they maintain a permanent or principal residence, a usual abode, or a centre of vital interests in Greece, meaning personal, financial or social relations. This test stands on its own and does not depend on a day count.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Greece - Information on residency for tax purposes (OECD AEOI portal)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Greece-Tax-Residency.pdf", "source_type": "official-guidance", "effective": "Income Tax Code, Law 4172/2013, Article 4(1)", "checked": "2026-11-08" }, { "id": "GR-RES-02", "title": "Continuous presence of more than 183 days", "kind": "day-count", "text": "An individual who is continuously present in Greece for a period exceeding 183 days, including short periods abroad, is treated as tax resident from their first day of presence in Greece. This does not apply to people present only for tourism, medical treatment or similar private purposes whose presence does not exceed 365 days, including short periods abroad. The day-count rule does not replace the ties test in GR-RES-01.", "threshold_days": 183, "window": null, "day_method": null, "source_title": "Greece - Information on residency for tax purposes (OECD AEOI portal)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Greece-Tax-Residency.pdf", "source_type": "official-guidance", "effective": "Income Tax Code, Law 4172/2013, Article 4(2)", "checked": "2026-11-08" }, { "id": "GR-RES-03", "title": "Greek officials serving abroad", "kind": "citizenship", "text": "Consular, diplomatic or similar public officials, and public servants with Greek nationality who serve abroad, are treated as Greek tax residents.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Greece - Information on residency for tax purposes (OECD AEOI portal)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Greece-Tax-Residency.pdf", "source_type": "official-guidance", "effective": "Income Tax Code, Law 4172/2013, Article 4(1)", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Under GR-RES-02, residence based on presence of more than 183 days starts from the first day of presence in Greece. The sources checked do not set out departure rules; check the current AADE guidance.", "reporting": [], "social_security": "Greece applies the EU rules on social security coordination: a person is generally covered by one country's system at a time, and a PD A1 form can show continued home-country cover during a temporary posting. Check national contribution rules with the Greek social security authorities.", "living_base": "EU citizens can stay in Greece for up to three months without registering and may need to register for longer stays; after five years of continuous lawful residence they acquire the right of permanent residence. Non-EU nationals generally need a national visa or residence permit, handled by the Ministry of Migration and Asylum. A permit or registration does not by itself decide tax residence; the tests above do.", "citizenship": "Greek citizenship is acquired mainly by descent or by naturalization after a period of lawful residence, with other routes set by national law. This record has not verified the current residence period or the position on dual citizenship; check the competent Greek authority's current guidance.", "questions": [ "Where is my permanent or principal residence, usual abode or centre of vital interests for Greek purposes, and what evidence supports it?", "Has my presence in Greece been continuous for more than 183 days, and from which date would residence start?", "Does the exception for tourism, medical or similar private stays apply to my presence in Greece?", "Does any special regime for people who transfer tax residence to Greece apply to me, and what conditions does current AADE guidance set?", "Does another country also treat me as tax resident, and how does the tax treaty decide my residence?", "What happens to my Greek residence status in the year I leave Greece?" ], "authorities": [ { "title": "Independent Authority for Public Revenue (AADE)", "url": "https://www.aade.gr/en" }, { "title": "Ministry of Migration and Asylum", "url": "https://migration.gov.gr/en/" } ], "sources": [ { "title": "Greece - Information on residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Greece-Tax-Residency.pdf", "type": "official-guidance" }, { "title": "Income taxes abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/taxes/income-taxes-abroad/index_en.htm", "type": "official-guidance" }, { "title": "Double taxation - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/taxes/double-taxation/index_en.htm", "type": "official-guidance" }, { "title": "Social security cover when you live or work in another EU country - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights when living abroad in the EU - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "hr", "name": "Croatia", "slug": "croatia", "region": "Europe", "flag": "🇭🇷", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "residence", "summary": "Croatia treats an individual as tax resident if they have a domicile or a habitual residence in Croatia, and residents are taxed on income from Croatia and abroad. Domicile can arise from owning or possessing a dwelling for at least 183 days in one or two calendar years even without living in it, and habitual residence from a stay of at least 183 days in one or two calendar years.", "residence_rules": [ { "id": "HR-RES-01", "title": "Domicile through a dwelling (prebivalište)", "kind": "ties", "text": "A person has a domicile for tax purposes where they own or possess a dwelling continuously for at least 183 days in one or two calendar years. Actually staying in the dwelling is not required. If the person has several dwellings in Croatia, the family's place of residence decides, and for a single person the place where they mainly stay or from which they mainly leave for work.", "threshold_days": null, "window": "multi-year", "day_method": null, "source_title": "Prebivalište/uobičajeno boravište za porezne svrhe - Porezna uprava", "source_url": "https://porezna-uprava.gov.hr/hr/prebivaliste-uobicajeno-boraviste/4631", "source_type": "official-guidance", "effective": "General Tax Act and Income Tax Act, as described by the Tax Administration", "checked": "2026-11-08" }, { "id": "HR-RES-02", "title": "Habitual residence (uobičajeno boravište)", "kind": "day-count", "text": "Habitual residence is considered where a person has a continuous or time-linked stay of at least 183 days in one or two calendar years, in circumstances showing the stay is not only temporary. Short interruptions of up to one year are disregarded. The Tax Administration applies this test only where domicile cannot be determined under HR-RES-01.", "threshold_days": 183, "window": "multi-year", "day_method": null, "source_title": "Prebivalište/uobičajeno boravište za porezne svrhe - Porezna uprava", "source_url": "https://porezna-uprava.gov.hr/hr/prebivaliste-uobicajeno-boraviste/4631", "source_type": "official-guidance", "effective": "General Tax Act, as described by the Tax Administration", "checked": "2026-11-08" }, { "id": "HR-RES-03", "title": "Croatian civil servants without domicile in Croatia", "kind": "ties", "text": "A person who has neither domicile nor habitual residence in Croatia is still resident if they are employed in the civil service of the Republic of Croatia and receive a salary on that basis.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Općenito o dohotku - Porezna uprava", "source_url": "https://porezna-uprava.gov.hr/hr/opcenito-o-dohotku/4774", "source_type": "official-guidance", "effective": "Income Tax Act, Article 3", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "The tax period is generally the calendar year, but it can be shorter when a person's residence status changes during the year. The Tax Administration uses Form TU for a change to resident status and Form TI for a change away from resident status (HR-RES-01 and HR-RES-02).", "reporting": [ { "title": "Forms TU and TI: change of residence status", "text": "Form TU records a change to resident status and Form TI a change away from resident status, for example when a person asks to be removed from the register of taxpayers. Answers cover stays in and outside Croatia and ties to Croatia and other states, supported by documents such as a residence certificate from another state.", "source_url": "https://porezna-uprava.gov.hr/hr/utvrdjivanje-rezidentnosti-u-porezne-svrhe/3998" } ], "social_security": "Croatia applies the EU rules on social security coordination: a person is generally covered by one country's system at a time, and a PD A1 form can show continued home-country cover during a temporary posting. Check national contribution rules with the Croatian social security authorities.", "living_base": "EU citizens can stay in Croatia for up to three months without registering and may need to register for longer stays; after five years of continuous lawful residence they acquire the right of permanent residence. Non-EU nationals generally need a visa or residence permit, handled by the Ministry of the Interior. A permit or registration does not by itself decide tax residence; the domicile and habitual residence tests do.", "citizenship": "Croatian citizenship is acquired mainly by descent or by naturalization after a period of lawful residence, with other routes set by national law. This record has not verified the current residence period or the position on dual citizenship; check the Ministry of the Interior's current guidance.", "questions": [ "Do I own or possess a dwelling in Croatia that could create a domicile for tax purposes, even if I rarely stay there?", "How many days have I stayed in Croatia across one or two calendar years, and do any breaks count as short interruptions?", "Should Form TU or Form TI be filed for my change of status, and what documents support it?", "Does another country also treat me as tax resident, and how does the tax treaty decide my residence?", "Which of my income from abroad is taxable in Croatia while I am resident?", "How is my tax period set in the year my residence status changes?" ], "authorities": [ { "title": "Porezna uprava (Tax Administration)", "url": "https://porezna-uprava.gov.hr/en" }, { "title": "Ministry of the Interior", "url": "https://mup.gov.hr/" } ], "sources": [ { "title": "Prebivalište/uobičajeno boravište za porezne svrhe - Porezna uprava", "url": "https://porezna-uprava.gov.hr/hr/prebivaliste-uobicajeno-boraviste/4631", "type": "official-guidance" }, { "title": "Općenito o dohotku - Porezna uprava", "url": "https://porezna-uprava.gov.hr/hr/opcenito-o-dohotku/4774", "type": "official-guidance" }, { "title": "Utvrđivanje rezidentnosti u porezne svrhe - Porezna uprava", "url": "https://porezna-uprava.gov.hr/hr/utvrdjivanje-rezidentnosti-u-porezne-svrhe/3998", "type": "official-guidance" }, { "title": "Croatia - Information on residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Croatia-Tax-Residency.pdf", "type": "official-guidance" }, { "title": "Social security cover when you live or work in another EU country - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights when living abroad in the EU - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "hu", "name": "Hungary", "slug": "hungary", "region": "Europe", "flag": "🇭🇺", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "residence", "summary": "Hungary treats Hungarian citizens as resident individuals, except dual citizens without a registered Hungarian address, and also treats as resident EEA nationals who exercise free-movement rights in Hungary for at least 183 days in a calendar year, third-country nationals with long-term residence status, and stateless persons. Anyone else is resident if Hungary is their only permanent home, their centre of vital interests, or, failing both, their habitual residence; treaties then settle cases where two countries both claim a person.", "residence_rules": [ { "id": "HU-RES-01", "title": "Hungarian citizens", "kind": "citizenship", "text": "Under Section 3(2) of the Personal Income Tax Act (Act CXVII of 1995), a Hungarian citizen is a resident private individual, except a dual citizen who has no registered address in Hungary. NAV guidance notes that a Hungarian citizen can stay resident under Hungarian law while living and working abroad for several years, and may at the same time be resident in the other country, in which case the tax treaty decides.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Magánszemélyek külföldről származó jövedelme (NAV információs füzet, közzétéve 2025. 02. 11.)", "source_url": "https://nav.gov.hu/pfile/file?path=%2Fugyfeliranytu%2Fnezzen-utana%2Finf_fuz%2F2025%2F04.-Maganszemelyek-kulfoldrol-szarmazo-jovedelme-2025.02.11", "source_type": "official-guidance", "effective": "Act CXVII of 1995 on Personal Income Tax, Section 3(2)", "checked": "2026-11-08" }, { "id": "HU-RES-02", "title": "EEA nationals: 183 days in a calendar year", "kind": "day-count", "text": "A person who exercises the right of free movement and residence, mainly an EU or EEA national, is resident if they exercise that right in Hungary for at least 183 days in the calendar year. The government's information sheet on the OECD portal states that the day of entry and the day of exit are included in the count.", "threshold_days": 183, "window": "calendar-year", "day_method": "official-guidance", "source_title": "Hungary - Information on Residency for tax purposes (OECD AEOI portal)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Hungary-Tax-Residence.pdf", "source_type": "official-guidance", "effective": "Act CXVII of 1995 on Personal Income Tax, Section 3(2)", "checked": "2026-11-08" }, { "id": "HU-RES-03", "title": "Third-country nationals with long-term residence status, and stateless persons", "kind": "registration", "text": "A third-country national who holds long-term (permanent) residence status under Hungary's immigration rules is resident, as is a stateless person.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Magánszemélyek külföldről származó jövedelme (NAV információs füzet, közzétéve 2025. 02. 11.)", "source_url": "https://nav.gov.hu/pfile/file?path=%2Fugyfeliranytu%2Fnezzen-utana%2Finf_fuz%2F2025%2F04.-Maganszemelyek-kulfoldrol-szarmazo-jovedelme-2025.02.11", "source_type": "official-guidance", "effective": "Act CXVII of 1995 on Personal Income Tax, Section 3(2)", "checked": "2026-11-08" }, { "id": "HU-RES-04", "title": "Others: permanent home, centre of vital interests, habitual residence", "kind": "ties", "text": "A person not covered by HU-RES-01 to HU-RES-03 is resident if their only permanent home is in Hungary. If they have no permanent home, or have one in Hungary and another country, they are resident if their centre of vital interests, meaning their closest personal, family and economic ties, is in Hungary. If that cannot be determined, they are resident if their habitual residence is in Hungary. A permanent home is where the person has settled to live long term and actually lives, and a temporary longer stay abroad does not change it.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Magánszemélyek külföldről származó jövedelme (NAV információs füzet, közzétéve 2025. 02. 11.)", "source_url": "https://nav.gov.hu/pfile/file?path=%2Fugyfeliranytu%2Fnezzen-utana%2Finf_fuz%2F2025%2F04.-Maganszemelyek-kulfoldrol-szarmazo-jovedelme-2025.02.11", "source_type": "official-guidance", "effective": "Act CXVII of 1995 on Personal Income Tax, Section 3(2)", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Residence can change within a tax year when a person's circumstances change, and income earned before and after the change is taxed differently; NAV's example uses the tax treaty to set the date of change. NAV guidance also says a person leaving Hungary permanently may ask NAV to assess their tax by formal decision ahead of the usual schedule, under Section 148(1) of the Act on the Rules of Taxation; check with NAV how that interacts with the annual return.", "reporting": [], "social_security": "Hungary applies the EU rules on social security coordination: a person is generally covered by one country's system at a time, and a PD A1 form can show continued home-country cover during a temporary posting. Check national contribution rules with NAV and the Hungarian social security authorities.", "living_base": "EU citizens can stay in Hungary for up to three months without registering and may need to register for longer stays; after five years of continuous lawful residence they acquire the right of permanent residence. Non-EU nationals generally need a visa or residence permit, handled by the National Directorate-General for Aliens Policing. A residence permit alone does not decide tax residence, although long-term residence status is one of the tests in HU-RES-03.", "citizenship": "Hungarian citizenship is acquired mainly by descent or by naturalization after a period of lawful residence, with other routes set by national law. Hungarian citizenship itself is a tax residence test (HU-RES-01), with an exception for dual citizens without a registered Hungarian address. This record has not verified the current naturalization residence period; check the competent Hungarian authority's current guidance.", "questions": [ "Am I a Hungarian citizen, a dual citizen with or without a registered Hungarian address, an EEA national, or a third-country national with long-term residence status?", "If I am an EEA national, how many days, counting entry and exit days, have I exercised my residence right in Hungary in the calendar year?", "Where is my permanent home, and where is my centre of vital interests if I have homes in more than one country?", "Does another country also treat me as tax resident, and how does the tax treaty with Hungary decide my residence?", "If my residence changed during the year, on what date did it change and how is my income split?", "If I am leaving Hungary permanently, should I ask NAV to assess my tax by decision, and what does that involve?" ], "authorities": [ { "title": "National Tax and Customs Administration (NAV)", "url": "https://nav.gov.hu/en" }, { "title": "National Directorate-General for Aliens Policing (OIF)", "url": "https://oif.gov.hu/" } ], "sources": [ { "title": "Magánszemélyek külföldről származó jövedelme (NAV információs füzet, közzétéve 2025. 02. 11.)", "url": "https://nav.gov.hu/pfile/file?path=%2Fugyfeliranytu%2Fnezzen-utana%2Finf_fuz%2F2025%2F04.-Maganszemelyek-kulfoldrol-szarmazo-jovedelme-2025.02.11", "type": "official-guidance" }, { "title": "Hungary - Information on Residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Hungary-Tax-Residence.pdf", "type": "official-guidance" }, { "title": "Social security cover when you live or work in another EU country - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights when living abroad in the EU - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "ie", "name": "Ireland", "slug": "ireland", "region": "Europe", "flag": "🇮🇪", "tax_year": "1 January to 31 December", "tax_basis": "remittance-available", "summary": "Ireland decides tax residence by days present: 183 days or more in a tax year, or 280 days or more across the current and preceding tax years, and any part of a day counts. Residence, ordinary residence and domicile are separate tests, and Revenue describes a remittance basis for foreign income of a person who is tax resident but not ordinarily resident and not domiciled in Ireland.", "residence_rules": [ { "id": "IE-RES-01", "title": "183 days in one tax year", "kind": "day-count", "text": "A person is resident for a tax year if present in Ireland for 183 days or more in that year. Revenue counts a day if the person is in Ireland for any part of it, with exceptions such as staying airside at an airport or port, or being unavoidably delayed on a planned departure day.", "threshold_days": 183, "window": "tax-year", "day_method": "any-part", "source_title": "How to know if you are resident for tax purposes", "source_url": "https://www.revenue.ie/en/jobs-and-pensions/tax-residence/resident-for-tax-purposes.aspx", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "IE-RES-02", "title": "280 days across two tax years", "kind": "day-count", "text": "A person is also resident if present for 280 days or more in total over the current and the preceding tax year. Revenue states that a person is not resident under this test in a tax year with 30 days or less in Ireland.", "threshold_days": 280, "window": "multi-year", "day_method": "any-part", "source_title": "How to know if you are resident for tax purposes", "source_url": "https://www.revenue.ie/en/jobs-and-pensions/tax-residence/resident-for-tax-purposes.aspx", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "IE-RES-03", "title": "Ordinary residence and domicile", "kind": "registration", "text": "After three consecutive tax years of residence, a person becomes ordinarily resident from the start of the fourth year, and after leaving stays ordinarily resident for three more consecutive tax years. Domicile is a separate legal concept, broadly living in a country with the intention of living there permanently, and a domicile of origin continues unless clear evidence shows a new one. These statuses change which income is chargeable to Irish tax.", "threshold_days": null, "window": "multi-year", "day_method": null, "source_title": "How to know if you are ordinarily resident for tax purposes", "source_url": "https://www.revenue.ie/en/jobs-and-pensions/tax-residence/ordinarily-resident-tax-purposes.aspx", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Revenue describes split-year treatment for the year a person comes to live in Ireland and for the year a person leaves permanently to take up employment abroad; the conditions are on separate Revenue pages. A person arriving with the intention of being resident the following year can elect to be resident in the arrival year by informing Revenue in writing (relates to IE-RES-01 and IE-RES-02).", "reporting": [ { "title": "Election to be resident", "text": "Revenue states that a person who chooses to be tax resident in Ireland in a tax year must inform Revenue in writing.", "source_url": "https://www.revenue.ie/en/jobs-and-pensions/tax-residence/resident-for-tax-purposes.aspx" }, { "title": "Domicile levy", "text": "An annual levy of €200,000 may apply to Irish-domiciled individuals whose worldwide income exceeds €1m, whose Irish property is worth more than €5m and whose Irish income tax for the year was less than €200,000. Irish income tax paid in the year can be offset against it.", "source_url": "https://www.revenue.ie/en/jobs-and-pensions/tax-residence/domicile-domicile-levy.aspx" } ], "social_security": "Within the EU, a person is covered by one country's social security system at a time, and which one depends on work situation and residence, not nationality. Check the EU coordination rules and any bilateral agreement for work involving non-EU countries.", "living_base": "EU citizens can move to Ireland under EU free movement rules, with permanent residence after a continuous 5-year period of legal residence. Others generally need an immigration permission, and the type of permission affects whether time counts toward naturalisation. An immigration permission does not decide tax residence, which follows Revenue's day tests.", "citizenship": "Naturalisation is at the Minister's discretion and is based on reckonable residence; Immigration Service Delivery describes five years of reckonable residence that include one year of continuous residence immediately before the application, with a shorter route for spouses of Irish citizens. Immigration Service Delivery states that Irish law does not require giving up another citizenship to become Irish, although the other country's law may differ.", "questions": [ "How should my days in Ireland be counted under the 183-day and 280-day tests, including travel days?", "Am I ordinarily resident, and when would that status start or end for me?", "Where am I domiciled, and does the remittance basis described by Revenue apply to any of my foreign income?", "Does split-year treatment apply to my year of arrival or departure, and what are its conditions?", "Would an election to be resident in my arrival year change my position?", "If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?", "Does my immigration permission count as reckonable residence for naturalisation?" ], "authorities": [ { "title": "Revenue (Irish Tax and Customs)", "url": "https://www.revenue.ie" }, { "title": "Immigration Service Delivery", "url": "https://www.irishimmigration.ie" } ], "sources": [ { "title": "Tax residence", "url": "https://www.revenue.ie/en/jobs-and-pensions/tax-residence/index.aspx", "type": "official-guidance" }, { "title": "How to know if you are resident for tax purposes", "url": "https://www.revenue.ie/en/jobs-and-pensions/tax-residence/resident-for-tax-purposes.aspx", "type": "official-guidance" }, { "title": "How to know if you are ordinarily resident for tax purposes", "url": "https://www.revenue.ie/en/jobs-and-pensions/tax-residence/ordinarily-resident-tax-purposes.aspx", "type": "official-guidance" }, { "title": "What is domicile and the domicile levy?", "url": "https://www.revenue.ie/en/jobs-and-pensions/tax-residence/domicile-domicile-levy.aspx", "type": "official-guidance" }, { "title": "Moving to or from Ireland during the tax year", "url": "https://www.revenue.ie/en/jobs-and-pensions/tax-residence/moving-to-from-ireland.aspx", "type": "official-guidance" }, { "title": "Become an Irish citizen by naturalisation - Immigration Service Delivery", "url": "https://www.irishimmigration.ie/how-to-become-a-citizen/become-an-irish-citizen-by%20-naturalisation/", "type": "official-guidance" }, { "title": "Dual Citizenship - Immigration Service Delivery", "url": "https://www.irishimmigration.ie/how-to-become-a-citizen/dual-citizenship/", "type": "official-guidance" }, { "title": "Social security cover abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "il", "name": "Israel", "slug": "israel", "region": "Middle East", "flag": "🇮🇱", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "residence", "summary": "Israel treats an individual as resident when the center of life is in Israel, weighing family, economic and social ties. Two day-count presumptions (183 days, or 30 days plus 425 days over three years) point to residence, but either the individual or the Assessing Officer can rebut them, so days alone do not settle the question.", "residence_rules": [ { "id": "IL-RES-01", "title": "Center of life test", "kind": "ties", "text": "An individual is an Israel resident if the center of life is in Israel. The Income Tax Ordinance looks at the totality of family, economic and social ties, including the permanent home, where the person and family live, the regular place of business or employment, active and substantive economic interests, and activity in organizations and institutions.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Israel: Information on residency for tax purposes (Israel Tax Authority submission to the OECD, quoting the Income Tax Ordinance definition of resident)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Israel-Residency.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "IL-RES-02", "title": "183-day presumption", "kind": "presumption", "text": "The center of life is presumed to be in Israel for a tax year if the individual spent 183 days or more in Israel during that tax year. For this presumption a day includes part of a day. The presumption can be rebutted by the individual or by the Assessing Officer.", "threshold_days": 183, "window": "tax-year", "day_method": "any-part", "source_title": "Israel: Information on residency for tax purposes (Israel Tax Authority submission to the OECD)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Israel-Residency.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "IL-RES-03", "title": "30-day and 425-day presumption", "kind": "presumption", "text": "The center of life is also presumed to be in Israel if the individual spent 30 days or more in Israel in the tax year and the total stay in that tax year and the two years before it was 425 days or more. Part of a day counts as a day. This presumption is rebuttable in the same way as the 183-day presumption.", "threshold_days": 425, "window": "multi-year", "day_method": "any-part", "source_title": "Israel: Information on residency for tax purposes (Israel Tax Authority submission to the OECD)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Israel-Residency.pdf", "source_type": "official-guidance", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Relates to IL-RES-01. A Knesset Research and Information Center paper (July 2025) describes an optional adaptation year: a new immigrant, or a veteran returning resident (abroad at least ten years), can ask within 90 days of arrival not to be treated as an Israel resident for tax purposes in the first year. The same paper describes a ten-year exemption on foreign-source income under section 14 of the Ordinance for new immigrants and veteran returning residents, and a five-year exemption on part of foreign income for returning residents who were abroad six to ten years. Check the current Tax Authority guidance for the exact terms.", "reporting": [ { "title": "Foreign income reporting for new immigrants and veteran returning residents", "text": "New immigrants and veteran returning residents were exempt from reporting foreign-source income for ten years. The Knesset paper states that an April 2024 amendment requires those arriving from 2026 onward to report their foreign income, while the tax exemption continues to apply.", "source_url": "https://fs.knesset.gov.il/globaldocs/MMM/2ef1a063-cd62-f011-a85f-005056aa9911/2_2ef1a063-cd62-f011-a85f-005056aa9911_11_20997.pdf" } ], "social_security": "The National Insurance Institute decides residency for national insurance on a center-of-life basis, using an objective test (home, family, work, assets) and a subjective test, and only for people with a residency-granting status such as citizenship, permanent residence or certain A-type visas. Check the Institute's pages on social security conventions for cross-border cases.", "living_base": "Main routes to live in Israel include immigration under the Law of Return, permanent residence and A-type temporary residence visas issued through the Ministry of Interior and the Population and Immigration Authority. A visa or status does not by itself decide tax residence; the Tax Authority applies the center-of-life test.", "citizenship": "Israeli citizenship rests mainly on the Law of Return, 1950 and the Citizenship Law, 1952, which cover immigration, birth and naturalization. Residence periods for naturalization and the position on dual citizenship are not stated here; check the Population and Immigration Authority.", "questions": [ "Which of my family, economic and social ties would the Tax Authority weigh in deciding where my center of life is?", "If my day count meets the 183-day or 425-day presumption, what evidence would be needed to rebut it?", "If my day count is below both presumptions, could I still be treated as resident because of my ties?", "As a new immigrant or returning resident arriving in 2026 or later, what foreign income and assets would I need to report?", "Does the adaptation year make sense in my situation, and what is the deadline to request it?", "How would a tax treaty tie-breaker apply if another country also treats me as resident?", "How does my national insurance residency interact with my tax residency?" ], "authorities": [ { "title": "Israel Tax Authority", "url": "https://www.gov.il/en/departments/israel_tax_authority" }, { "title": "Population and Immigration Authority", "url": "https://www.gov.il/en/departments/population_and_immigration_authority" }, { "title": "National Insurance Institute of Israel", "url": "https://www.btl.gov.il/English%20Homepage/" } ], "sources": [ { "title": "Israel: Information on residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Israel-Residency.pdf", "type": "official-guidance" }, { "title": "Description and analysis of tax benefits for new immigrants and returning residents (Knesset Research and Information Center, 15 July 2025, Hebrew)", "url": "https://fs.knesset.gov.il/globaldocs/MMM/2ef1a063-cd62-f011-a85f-005056aa9911/2_2ef1a063-cd62-f011-a85f-005056aa9911_11_20997.pdf", "type": "official-guidance" }, { "title": "Who is an Israeli resident? (National Insurance Institute)", "url": "https://www.btl.gov.il/English%20Homepage/Insurance/An%20Insured%20Person%20Residing%20Abroad/Pages/Whois.aspx", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "in", "name": "India", "slug": "india", "region": "Asia", "flag": "🇮🇳", "tax_year": "1 April to 31 March", "tax_basis": "residence", "summary": "India decides residence by days of stay in the tax year and the preceding years: 182 days, or 60 days plus 365 days over the previous four years, with special variants for Indian citizens and persons of Indian origin. Residents are further split into ordinarily resident and not ordinarily resident, and an Indian citizen with Indian income above Rs 15 lakh who is not liable to tax elsewhere can be deemed resident.", "residence_rules": [ { "id": "IN-RES-01", "title": "182-day test", "kind": "day-count", "text": "An individual is resident if he stays in India for 182 days or more in the relevant tax year. The Income Tax Department states that the Income Tax Act, 2025 keeps the same basic conditions as section 6(1) of the Income Tax Act, 1961.", "threshold_days": 182, "window": "tax-year", "day_method": null, "source_title": "Income Tax Department: Non Resident FAQs", "source_url": "https://www.incometax.gov.in/iec/foportal/help/all-topics/e-filing-services/non%20resident%20-faq", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "IN-RES-02", "title": "60-day plus 365-day test", "kind": "day-count", "text": "An individual is also resident if he stays in India 60 days or more in the tax year and 365 days or more in the four preceding years. This limb does not apply to an Indian citizen leaving India for employment abroad or as crew of an Indian ship; for them only the 182-day test applies.", "threshold_days": 60, "window": "multi-year", "day_method": null, "source_title": "Income Tax Department: Non Resident FAQs", "source_url": "https://www.incometax.gov.in/iec/foportal/help/all-topics/e-filing-services/non%20resident%20-faq", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "IN-RES-03", "title": "120-day variant for visiting citizens and persons of Indian origin", "kind": "day-count", "text": "For an Indian citizen or person of Indian origin visiting India whose income other than foreign-source income exceeds Rs 15 lakh in the tax year, the 60-day limb reads as 120 days, with 365 days or more in the four preceding years. A person resident only under this route is treated as not ordinarily resident.", "threshold_days": 120, "window": "multi-year", "day_method": null, "source_title": "Income Tax Department: Non Resident FAQs; Residential Status in India", "source_url": "https://wm.incometaxindia.gov.in/web/guest/w/residential-status-in-india/residence-in-india-for-the-purpose-of-the-income-tax-act", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "IN-RES-04", "title": "Deemed resident citizen", "kind": "citizenship", "text": "An Indian citizen whose total income, other than income from foreign sources, exceeds Rs 15 lakh and who is not liable to tax in any other country by reason of domicile, residence or similar criteria is deemed resident, whatever the days in India. This rule is section 6(1A) of the 1961 Act and section 6(7) of the 2025 Act, and such a person is treated as not ordinarily resident.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Income Tax Department: Non Resident FAQs", "source_url": "https://www.incometax.gov.in/iec/foportal/help/all-topics/e-filing-services/non%20resident%20-faq", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "IN-RES-05", "title": "Not ordinarily resident (NOR)", "kind": "day-count", "text": "A resident individual is not ordinarily resident in a tax year if he was non-resident in nine out of the ten preceding years, or stayed in India for 729 days or less in the preceding seven years. Section 6(13) of the 2025 Act mirrors section 6(6) of the 1961 Act.", "threshold_days": 729, "window": "multi-year", "day_method": null, "source_title": "Income Tax Department: Non Resident FAQs", "source_url": "https://www.incometax.gov.in/iec/foportal/help/all-topics/e-filing-services/non%20resident%20-faq", "source_type": "official-guidance", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": null, "reporting": [ { "title": "Schedule FA: foreign assets and foreign-source income", "text": "Income tax return forms such as ITR-2 include Schedule FA, Details of Foreign Assets and Income from any source outside India, which the form marks as applicable to residents. Check the current form instructions for which residents must complete it.", "source_url": "https://www.incometax.gov.in/iec/foportal/sites/default/files/2023-04/ITR2_Notified%20Form%20AY%202023-24.pdf" } ], "social_security": null, "living_base": "Foreign nationals live in India on visas issued under Ministry of Home Affairs rules. Tax residence is decided by days of stay and the citizenship-linked rules above, not by the visa held.", "citizenship": "Indian citizenship is governed by the Citizenship Act, 1955 and administered by the Ministry of Home Affairs. Routes, residence periods and the position on dual citizenship are not stated here; check the Ministry's current guidance.", "questions": [ "How many days was I in India in the tax year and in each of the preceding years?", "Am I an Indian citizen or person of Indian origin visiting India, and does the 120-day variant apply to me?", "Could the deemed residency rule apply because I am not liable to tax anywhere else?", "Am I ordinarily resident or not ordinarily resident this year, and what does that change?", "Does the Income Tax Act, 2025 or the 1961 Act govern the year I am asking about?", "Do I need to complete Schedule FA for my foreign accounts and assets?", "How would a tax treaty tie-breaker apply if another country also treats me as resident?" ], "authorities": [ { "title": "Income Tax Department", "url": "https://www.incometax.gov.in/" }, { "title": "Ministry of Home Affairs", "url": "https://www.mha.gov.in/" } ], "sources": [ { "title": "Non Resident FAQs (Income Tax Department e-filing portal)", "url": "https://www.incometax.gov.in/iec/foportal/help/all-topics/e-filing-services/non%20resident%20-faq", "type": "official-guidance" }, { "title": "Residential Status in India / Residence in India for the purpose of the Income-tax Act (Income Tax Department)", "url": "https://wm.incometaxindia.gov.in/web/guest/w/residential-status-in-india/residence-in-india-for-the-purpose-of-the-income-tax-act", "type": "official-guidance" }, { "title": "ITR-2 Indian Income Tax Return form, AY 2023-24 (Schedule FA)", "url": "https://www.incometax.gov.in/iec/foportal/sites/default/files/2023-04/ITR2_Notified%20Form%20AY%202023-24.pdf", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "it", "name": "Italy", "slug": "italy", "region": "Europe", "flag": "🇮🇹", "tax_year": "1 January to 31 December", "tax_basis": "residence", "summary": "From the 2024 tax period, as amended by Legislative Decree 209/2023, a person is resident in Italy if for most of the tax period (183 days, or 184 in a leap year) they have their civil-law residence or their domicile in Italy, are physically present in Italy counting fractions of a day, or are enrolled in the resident population registry. Any one criterion is enough, registry enrolment is now a rebuttable presumption, and domicile now means the place where personal and family relationships mainly develop.", "residence_rules": [ { "id": "IT-RES-01", "title": "Physical presence for most of the tax period", "kind": "day-count", "text": "Physical presence in Italy for most of the tax period is a standalone criterion from 2024. Any fraction of a day spent within Italy counts toward the total, and non-consecutive periods are added together.", "threshold_days": 183, "window": "calendar-year", "day_method": "any-part", "source_title": "Circular No. 20/E of 4 November 2024 (courtesy translation)", "source_url": "https://www.agenziaentrate.gov.it/portale/documents/20143/6519685/Circolare_20_del_4_11_2024_Eng.pdf/bdacb2e0-a699-5180-719e-665210459d75", "source_type": "official-guidance", "effective": "Tax periods from 2024", "checked": "2026-11-08" }, { "id": "IT-RES-02", "title": "Civil-law residence or domicile", "kind": "ties", "text": "A person is also resident if, for most of the tax period, they have their residence within the meaning of the civil code, or their domicile, in Italy. Domicile is defined for tax purposes as the place where the person's personal and family relationships mainly develop, which gives priority to those relationships over economic ones.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "Circular No. 20/E of 4 November 2024 (courtesy translation)", "source_url": "https://www.agenziaentrate.gov.it/portale/documents/20143/6519685/Circolare_20_del_4_11_2024_Eng.pdf/bdacb2e0-a699-5180-719e-665210459d75", "source_type": "official-guidance", "effective": "Tax periods from 2024", "checked": "2026-11-08" }, { "id": "IT-RES-03", "title": "Enrolment in the resident population registry", "kind": "presumption", "text": "Enrolment in the resident population registry for most of the tax period remains a criterion, but since the 2024 reform it is a rebuttable presumption that admits contrary proof rather than an absolute one. For periods up to 2023, the former rules apply.", "threshold_days": 183, "window": "calendar-year", "day_method": null, "source_title": "Circular No. 20/E of 4 November 2024 (courtesy translation)", "source_url": "https://www.agenziaentrate.gov.it/portale/documents/20143/6519685/Circolare_20_del_4_11_2024_Eng.pdf/bdacb2e0-a699-5180-719e-665210459d75", "source_type": "official-guidance", "effective": "Tax periods from 2024", "checked": "2026-11-08" }, { "id": "IT-RES-04", "title": "Italian citizens moving to a privileged tax regime", "kind": "citizenship", "text": "Italian citizens removed from the resident population registry who move to a state or territory on the privileged tax regime list are presumed resident in Italy unless they prove otherwise. The 2024 reform did not change this rule, and Switzerland was removed from the list from 1 January 2024.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "Circular No. 20/E of 4 November 2024 (courtesy translation)", "source_url": "https://www.agenziaentrate.gov.it/portale/documents/20143/6519685/Circolare_20_del_4_11_2024_Eng.pdf/bdacb2e0-a699-5180-719e-665210459d75", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "The criteria are tested for most of the tax period (183 days, or 184 in a leap year) within a calendar year, adding non-consecutive periods (IT-RES-01 to IT-RES-03). Check Circular 20/E and the relevant tax treaty for the year of arrival or departure.", "reporting": [ { "title": "Registry and consular declarations on moving abroad", "text": "Circular 20/E recalls that Italian citizens must declare a transfer of residence abroad to the consular office within 90 days, alongside municipal registry declarations, and that registry status is relevant to the presumption in IT-RES-03.", "source_url": "https://www.agenziaentrate.gov.it/portale/documents/20143/6519685/Circolare_20_del_4_11_2024_Eng.pdf/bdacb2e0-a699-5180-719e-665210459d75" }, { "title": "Optional substitute tax for new residents (article 24-bis TUIR)", "text": "An option for individuals who transfer their tax residence to Italy to pay a substitute tax on foreign-source income. The rules were amended by Decree-Law 113/2024 and by Law 199/2025, so check the current amount and conditions in the official text.", "source_url": "https://www.agenziaentrate.gov.it/portale/schede/agevolazioni/opzione-per-i-neo-residenti/normativa-e-prassi-regi-opz-neo-residenti-cittadini" } ], "social_security": "Within the EU, a person is covered by one country's social security system at a time, and which one depends on work situation and residence, not nationality. Check the EU coordination rules and any bilateral agreement for work involving non-EU countries.", "living_base": "EU citizens can move to Italy under EU free movement rules, with permanent residence after a continuous 5-year period of legal residence. Others generally need a visa and a residence permit. A permit does not decide tax residence, which follows article 2 of the TUIR.", "citizenship": "The Ministry of the Interior states that foreign nationals who have resided in Italy for at least ten years can apply for citizenship, among other requirements; citizenship by marriage is handled by the prefecture. Decree-Law 36/2025, converted by Law 74/2025, limited automatic citizenship by descent for people born abroad who hold another citizenship to the exceptions in article 3-bis of Law 91/1992. The Ministry of Foreign Affairs states that Law 91/1992 recognises the right to hold multiple citizenships.", "questions": [ "How should my days of physical presence in Italy be counted, including fractions of a day?", "Where do my personal and family relationships mainly develop, and does that place my domicile in Italy?", "If I am enrolled in the registry, what evidence could rebut the presumption of residence?", "Does the presumption for Italian citizens in privileged tax regime countries apply to me?", "Would the article 24-bis option or any other regime for new residents apply, and what are the current amounts and conditions?", "If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?", "Do the 2025 descent rules affect any claim to Italian citizenship in my family?" ], "authorities": [ { "title": "Agenzia delle Entrate", "url": "https://www.agenziaentrate.gov.it" }, { "title": "Ministero dell'Interno (cittadinanza)", "url": "https://www.interno.gov.it" }, { "title": "Ministero degli Affari Esteri e della Cooperazione Internazionale", "url": "https://www.esteri.it" } ], "sources": [ { "title": "Circular No. 20/E of 4 November 2024 (courtesy translation)", "url": "https://www.agenziaentrate.gov.it/portale/documents/20143/6519685/Circolare_20_del_4_11_2024_Eng.pdf/bdacb2e0-a699-5180-719e-665210459d75", "type": "official-guidance" }, { "title": "Cittadini - Neo residenti - Regime opzionale - Normativa e prassi", "url": "https://www.agenziaentrate.gov.it/portale/schede/agevolazioni/opzione-per-i-neo-residenti/normativa-e-prassi-regi-opz-neo-residenti-cittadini", "type": "official-guidance" }, { "title": "Cittadinanza | Ministero dell'Interno", "url": "https://www.interno.gov.it/it/temi/cittadinanza-e-altri-diritti-civili/cittadinanza", "type": "official-guidance" }, { "title": "Citizenship – Ministero degli Affari Esteri e della Cooperazione Internazionale", "url": "https://www.esteri.it/en/servizi-opportunita/italiani-all-estero/cittadinanza/", "type": "official-guidance" }, { "title": "Social security cover abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "jp", "name": "Japan", "slug": "japan", "region": "Asia", "flag": "🇯🇵", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "remittance-available", "summary": "Japan treats an individual as resident if they have a domicile (jusho) in Japan or have kept a residence (kyosho) there continuously for one year or more. Among residents, a non-Japanese national with five years or less of domicile or residence in the past ten years is a non-permanent resident, taxed on foreign-source income only when paid in or remitted to Japan.", "residence_rules": [ { "id": "JP-RES-01", "title": "Domicile (jusho): base of living", "kind": "ties", "text": "An individual with a domicile in Japan is a resident. The NTA explains that whether the base of living is in Japan is judged from objective facts, such as having an occupation in Japan, living with a spouse or other relatives, or owning a place of business.", "threshold_days": null, "window": null, "day_method": null, "source_title": "NTA: 2025 Income Tax and Special Income Tax for Reconstruction Guide, Taxpayers and the scope of taxable income", "source_url": "https://www.nta.go.jp/english/taxes/individual/pdf/incometax_2025/01.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "JP-RES-02", "title": "Residence (kyosho) for one year or more", "kind": "day-count", "text": "An individual without a domicile who has kept a residence in Japan continuously for one year or more is a resident. The NTA guide treats such a person as a non-resident until one year has passed from entry and as a resident after that.", "threshold_days": null, "window": null, "day_method": null, "source_title": "NTA: 2025 Income Tax Guide, Classification for residential status", "source_url": "https://www.nta.go.jp/english/taxes/individual/pdf/incometax_2025/01.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "JP-RES-03", "title": "Presumptions of domicile and temporary absence", "kind": "presumption", "text": "A person who comes to Japan for an occupation that normally requires living there continuously for one year or more is presumed to have a domicile, unless a contract clearly limits the stay to under one year. A person who leaves intending to be absent temporarily is treated as residing in Japan during the absence; that intention is presumed if, for example, a spouse or relatives stay in the household, a residence is kept for the return, or personal property for daily use stays in Japan.", "threshold_days": null, "window": null, "day_method": null, "source_title": "NTA: 2025 Income Tax Guide, Judgment (presumption) of the presence of a domicile", "source_url": "https://www.nta.go.jp/english/taxes/individual/pdf/incometax_2025/01.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "JP-RES-04", "title": "Non-permanent resident", "kind": "ties", "text": "A resident of non-Japanese nationality who has had a domicile or residence in Japan for an aggregate of five years or less within the preceding ten years is a non-permanent resident. Non-permanent residents are taxed on income other than foreign-source income, foreign-source income paid in Japan, and foreign-source income paid abroad and remitted to Japan.", "threshold_days": null, "window": "multi-year", "day_method": null, "source_title": "NTA: 2025 Income Tax Guide, Scope of taxable income", "source_url": "https://www.nta.go.jp/english/taxes/individual/pdf/incometax_2025/01.pdf", "source_type": "official-guidance", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Relates to JP-RES-01. The NTA guide covers years with both resident and non-resident periods, notes that some items depend on whether a tax agent is appointed when leaving Japan, and refers to an exit tax system: special treatment of income from the transfer of assets when departing Japan. Check current NTA guidance for exit tax thresholds and conditions.", "reporting": [ { "title": "Report of Foreign Assets", "text": "Residents other than non-permanent residents who own foreign assets exceeding 50 million yen as of 31 December must submit a report of foreign assets to the tax office. The 2025 guide gives 30 June 2026 as the due date for assets held on 31 December 2025.", "source_url": "https://www.nta.go.jp/english/taxes/individual/pdf/incometax_2025/01.pdf" } ], "social_security": null, "living_base": "Foreign nationals live in Japan under a status of residence administered by the Immigration Services Agency. Tax status depends on domicile or a one-year residence, not on the visa category, so a status of residence does not decide tax residence.", "citizenship": "The Ministry of Justice lists, among naturalization conditions, domicile in Japan for five or more consecutive years with a valid residence status. People who hold Japanese and another nationality are required to choose one by a deadline set in the Nationality Act, and may lose Japanese nationality in some cases if they do not.", "questions": [ "Where is my base of living, and which objective facts would the tax office look at?", "If I came to Japan for work, does my contract make the one-year domicile presumption apply?", "Am I a non-permanent resident, and how would my overseas remittances to Japan be treated?", "When I leave Japan, should I appoint a tax agent, and does the exit tax system apply to my assets?", "Do I need to file a Report of Foreign Assets?", "How would a tax treaty tie-breaker apply if another country also treats me as resident?" ], "authorities": [ { "title": "National Tax Agency", "url": "https://www.nta.go.jp/english/" }, { "title": "Immigration Services Agency of Japan", "url": "https://www.moj.go.jp/isa/" }, { "title": "Ministry of Justice (nationality)", "url": "https://www.moj.go.jp/EN/MINJI/minji78.html" } ], "sources": [ { "title": "2025 Income Tax and Special Income Tax for Reconstruction Guide (NTA)", "url": "https://www.nta.go.jp/english/taxes/individual/pdf/incometax_2025/01.pdf", "type": "official-guidance" }, { "title": "No.12006 Tax on the income of an individual who is a non-resident (NTA)", "url": "https://www.nta.go.jp/english/taxes/individual/12006.htm", "type": "official-guidance" }, { "title": "The Nationality Law (Ministry of Justice)", "url": "https://www.moj.go.jp/EN/MINJI/minji78.html", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "mt", "name": "Malta", "slug": "malta", "region": "Europe", "flag": "🇲🇹", "tax_year": "1 January to 31 December (basis year)", "tax_basis": "remittance-available", "summary": "Malta's Income Tax Act defines an individual resident in Malta as one who resides there, apart from temporary absences the Commissioner considers reasonable, and the scope of tax then depends on ordinary residence and domicile. For a person not ordinarily resident or not domiciled in Malta, foreign income is taxed on the amount received in Malta and foreign capital gains are not taxed, subject to a minimum tax for some non-domiciled individuals.", "residence_rules": [ { "id": "MT-RES-01", "title": "Residing in Malta", "kind": "ties", "text": "The Income Tax Act defines 'resident in Malta' for an individual as a person who resides in Malta, except for temporary absences that the Commissioner considers reasonable and not inconsistent with the claim to be resident. The definition itself does not set a day count.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Income Tax Act (Cap. 123), article 2", "source_url": "https://legislation.mt/eli/cap/123/eng/pdf", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "MT-RES-02", "title": "Ordinary residence and domicile set the scope of tax", "kind": "registration", "text": "Under the proviso to article 4(1), income arising outside Malta to a person who is not ordinarily resident or not domiciled in Malta is taxed on the amount received in Malta, and no tax is payable on capital gains arising outside Malta to such a person. Domicile is a legal status that is separate from residence.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Income Tax Act (Cap. 123), article 4(1)", "source_url": "https://legislation.mt/eli/cap/123/eng/pdf", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "MT-RES-03", "title": "Temporary residents", "kind": "day-count", "text": "Article 13 provides that tax is not payable on income arising outside Malta to a person who is in Malta for a temporary purpose only, without intent to establish residence, and who has not actually resided in Malta for periods equal in total to six months in the year preceding the year of assessment. The law states months, not a day number.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "Income Tax Act (Cap. 123), article 13", "source_url": "https://legislation.mt/eli/cap/123/eng/pdf", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": null, "reporting": [ { "title": "Minimum tax for some non-domiciled individuals (article 56(27))", "text": "An individual who is ordinarily resident but not domiciled in Malta, taxed under the remittance provisos, and who has at least €35,000 of foreign income that is not received or not fully received in Malta, is subject to a minimum tax of €5,000 per year, unless taxed under a scheme that already sets a minimum tax.", "source_url": "https://legislation.mt/eli/cap/123/eng/pdf" }, { "title": "Persons taxed at 15 cents in the euro (article 56(11))", "text": "The Act refers to persons charged at a rate of 0.15 in the euro under article 56(11), who are taxed only on income and gains arising in Malta and on foreign income received in Malta. Check the conditions of the specific scheme in the Act and subsidiary legislation.", "source_url": "https://legislation.mt/eli/cap/123/eng/pdf" } ], "social_security": "Within the EU, a person is covered by one country's social security system at a time, and which one depends on work situation and residence, not nationality. Check the EU coordination rules and any bilateral agreement for work involving non-EU countries.", "living_base": "EU citizens can move to Malta under EU free movement rules, with permanent residence after a continuous 5-year period of legal residence. Others generally need a visa or residence permit. A residence permit or residence programme does not by itself decide tax residence, ordinary residence or domicile under the Income Tax Act.", "citizenship": "Under article 10 of the Maltese Citizenship Act, naturalisation generally requires residence in Malta for the 12 months immediately before the application and, in the six years before that, residence totalling at least four years, plus adequate knowledge of Maltese or English and good character. Article 7 provides that a person may lawfully be a citizen of Malta and of another country at the same time. On 29 April 2025 the Court of Justice of the EU held that Malta's 2020 investor citizenship scheme infringed EU law (Case C-181/23), and the Act was amended in 2025 (Act XXI of 2025).", "questions": [ "Would my presence and ties in Malta make me resident under the Income Tax Act, given that the definition sets no day count?", "Am I ordinarily resident in Malta, and where is my domicile?", "Which of my foreign income would count as received in Malta under the remittance provisos?", "Could the minimum tax under article 56(27) apply to me?", "Does any scheme taxed under article 56(11) apply, and what are its current conditions?", "If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?", "How do the 2025 amendments to the Maltese Citizenship Act affect the routes to citizenship?" ], "authorities": [ { "title": "Malta Tax and Customs Administration", "url": "https://mtca.gov.mt" }, { "title": "Identità (residence permits)", "url": "https://identita.gov.mt" }, { "title": "Community Malta Agency (citizenship)", "url": "https://komunita.gov.mt" } ], "sources": [ { "title": "Income Tax Act, Chapter 123 of the Laws of Malta", "url": "https://legislation.mt/eli/cap/123/eng/pdf", "type": "primary-law" }, { "title": "Maltese Citizenship Act, Chapter 188 of the Laws of Malta", "url": "https://legislation.mt/eli/cap/188/eng/pdf", "type": "primary-law" }, { "title": "Press Release No 52/25: Union citizenship: the Maltese investor citizenship scheme is contrary to EU law", "url": "https://curia.europa.eu/site/upload/docs/application/pdf/2025-04/cp250052en.pdf", "type": "official-guidance" }, { "title": "Social security cover abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "mx", "name": "Mexico", "slug": "mexico", "region": "North America", "flag": "🇲🇽", "tax_year": "Calendar year (año de calendario)", "tax_basis": "residence", "summary": "Mexico taxes its tax residents on all income wherever the source, and taxes people resident abroad only on Mexican-source income or income attributable to a Mexican permanent establishment. Residence for individuals is set in the Federal Tax Code (article 9) and starts from where the person has established a home (casa habitación), with a centre of vital interests test used alongside it.", "residence_rules": [ { "id": "MX-RES-01", "title": "Home in Mexico (casa habitación) and centre of vital interests", "kind": "ties", "text": "The Federal Tax Code (Código Fiscal de la Federación, article 9, fraction I, subparagraph a) treats individuals who have established their home in Mexico as residents. The Code's regulation (article 5) adds that people who only stay temporarily in property used for tourism, and whose centre of vital interests is not in Mexico, have not established a home there. The full article 9 text, including its vital-interests criteria and any presumption for Mexican nationals, should be read in the current official version of the Code.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Reglamento del Código Fiscal de la Federación, artículo 5 (DOF 2 April 2014)", "source_url": "https://www.gob.mx/cms/uploads/attachment/file/494010/Reglamento_del_C_digo_Fiscal_de_la_Federaci_n.pdf", "source_type": "primary-law", "effective": "Regulation published 2 April 2014", "checked": "2026-11-08" }, { "id": "MX-RES-02", "title": "Treaty tie-breaker when two countries treat a person as resident", "kind": "ties", "text": "Mexico's income tax treaties set tie-breaker rules for people resident in both countries under domestic law. In the treaty with Panama, for example, the person is resident only where they have a permanent home available; if they have one in both or neither, the country of closer personal and economic relations (centre of vital interests) decides, followed by further tests. Each treaty must be checked on its own terms.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Convenio Panamá–México para evitar la doble imposición, artículo 4 (Ley 24 de 31 de marzo de 2010, Panamá)", "source_url": "https://dgi.mef.gob.pa/Internacional/CONVENIOS/Mexico/Ley%2024%20de%2031%20de%20marzo%20de%202010%20Panam%C3%A1_M%C3%A9xico.pdf", "source_type": "treaty", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "As published in 2013, article 90 of the Income Tax Law says individuals who change their residence to another country during a calendar year treat their provisional payments as the final tax and cannot file an annual return. Check the current consolidated text and SAT guidance for the notice that must be given when tax residence changes. Relates to MX-RES-01.", "reporting": [ { "title": "Annual return (declaración anual)", "text": "Article 150 of the Income Tax Law requires individuals with income in a calendar year, apart from exempt income and income already taxed definitively, to pay their annual tax by a return filed in April of the following year, with some exceptions for people with only salary and limited interest income.", "source_url": "https://www.ordenjuridico.gob.mx/Documentos/Federal/pdf/wo88917.pdf" }, { "title": "Loans, gifts and prizes in the annual return", "text": "As published in 2013, article 90 of the Income Tax Law requires resident individuals to report loans, gifts and prizes received in the year in the annual return when they pass a set amount. Check the current amount and form with the SAT.", "source_url": "https://www.ordenjuridico.gob.mx/Documentos/Federal/pdf/wo88917.pdf" } ], "social_security": "Mexico appears on the CRA's list of countries with a social security agreement with Canada; check the Instituto Mexicano del Seguro Social and each agreement for coverage and terms.", "living_base": "Foreign nationals live in Mexico under temporary residence (residente temporal) or permanent residence (residente permanente). Mexican consulates list bases such as economic solvency, family unit, real estate in Mexico and investment for temporary residence, and retirement or pension, family unit and a points system for permanent residence, with the residence card issued by the Instituto Nacional de Migración after entry. A residence card does not decide tax residence, which follows the Federal Tax Code tests.", "citizenship": "Mexican nationality can be acquired by birth or by naturalization through a carta de naturalización issued by the Secretaría de Relaciones Exteriores, with routes based on residence, marriage to a Mexican national and origin in a Latin American or Iberian country. The residence periods and any rules on keeping a prior nationality were not verified from an official page for this record; check the current SRE requirements.", "questions": [ "Where is my casa habitación for Mexican tax purposes if I keep homes in more than one country?", "How would the centre of vital interests criteria in article 9 of the Federal Tax Code apply to my income and professional activity?", "If I am a Mexican national living abroad, what does the current Code say about proving residence elsewhere?", "What notice must I give the SAT when my tax residence changes, and when is it due?", "How would the tie-breaker article of the relevant tax treaty apply to me if another country also treats me as resident?", "Which of my foreign-source income items must be declared in my Mexican annual return as a resident?", "Does my residence card category affect any of my tax or social security obligations?" ], "authorities": [ { "title": "Servicio de Administración Tributaria (SAT)", "url": "https://www.sat.gob.mx" }, { "title": "Instituto Nacional de Migración (INM)", "url": "https://www.gob.mx/inm" }, { "title": "Secretaría de Relaciones Exteriores (SRE)", "url": "https://www.gob.mx/sre" } ], "sources": [ { "title": "Ley del Impuesto sobre la Renta (published DOF 11 December 2013), Orden Jurídico Nacional", "url": "https://www.ordenjuridico.gob.mx/Documentos/Federal/pdf/wo88917.pdf", "type": "primary-law" }, { "title": "Reglamento del Código Fiscal de la Federación (DOF 2 April 2014)", "url": "https://www.gob.mx/cms/uploads/attachment/file/494010/Reglamento_del_C_digo_Fiscal_de_la_Federaci_n.pdf", "type": "primary-law" }, { "title": "Convenio entre Panamá y México para evitar la doble imposición (DGI Panamá)", "url": "https://dgi.mef.gob.pa/Internacional/CONVENIOS/Mexico/Ley%2024%20de%2031%20de%20marzo%20de%202010%20Panam%C3%A1_M%C3%A9xico.pdf", "type": "treaty" }, { "title": "Tipos de Visa 2025 (Consulado General de México en Houston)", "url": "https://consulmex.sre.gob.mx/houston/index.php/tipos-de-visa-2025", "type": "official-guidance" }, { "title": "What is the purpose of international social security agreements? (CRA)", "url": "https://www.canada.ca/en/revenue-agency/services/tax/canada-pension-plan-cpp-employment-insurance-ei-rulings/international-social-security-agreements-canada-pension-plan/what-purpose-international-social-security-agreements.html", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "my", "name": "Malaysia", "slug": "malaysia", "region": "Asia", "flag": "🇲🇾", "tax_year": "Calendar year basis year for each year of assessment", "tax_basis": "territorial", "summary": "Malaysia decides residence by physical presence in the basis year, not by nationality, under four routes in section 7 of the Income Tax Act 1967, starting with 182 days or more. Malaysia taxes income accruing in or derived from Malaysia; an LHDN guideline (June 2024) states that foreign income other than partnership income received by resident individuals from 1 January 2022 until 31 December 2026 is exempt if it was taxed in the country of origin.", "residence_rules": [ { "id": "MY-RES-01", "title": "182 days in the basis year", "kind": "day-count", "text": "An individual is resident for a basis year if in Malaysia for periods amounting in all to 182 days or more. Presence for part of a day counts as a whole day. Malaysian citizens are not automatically resident; the same rules apply.", "threshold_days": 182, "window": "calendar-year", "day_method": "any-part", "source_title": "LHDN Public Ruling No. 11/2017: Residence Status of Individuals, paragraph 6.1 (section 7(1)(a))", "source_url": "https://www.hasil.gov.my/wp-content/uploads/PR_11_2017.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "MY-RES-02", "title": "Under 182 days linked to an adjacent 182-day period", "kind": "day-count", "text": "An individual in Malaysia for less than 182 days in a basis year is resident if that period is linked to a period of 182 or more consecutive days in the preceding or following basis year. Temporary absences for service in Malaysia, ill-health of the individual or immediate family, or social visits not exceeding 14 days in aggregate can form part of the period if the person is in Malaysia immediately before and after.", "threshold_days": 182, "window": "multi-year", "day_method": "any-part", "source_title": "LHDN Public Ruling No. 11/2017, paragraph 6.2 (section 7(1)(b))", "source_url": "https://www.hasil.gov.my/wp-content/uploads/PR_11_2017.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "MY-RES-03", "title": "90 days plus prior years", "kind": "day-count", "text": "An individual in Malaysia for 90 days or more in a basis year is resident if, in any three of the four preceding years of assessment, he was either resident or in Malaysia for 90 days or more. The days need not be consecutive.", "threshold_days": 90, "window": "multi-year", "day_method": "any-part", "source_title": "LHDN Public Ruling No. 11/2017, paragraph 6.3 (section 7(1)(c))", "source_url": "https://www.hasil.gov.my/wp-content/uploads/PR_11_2017.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "MY-RES-04", "title": "Resident in the following year and three preceding years", "kind": "presumption", "text": "An individual is resident for a basis year, even with little or no presence, if resident for the immediately following basis year and for each of the three immediately preceding basis years.", "threshold_days": null, "window": "multi-year", "day_method": null, "source_title": "LHDN Public Ruling No. 11/2017, paragraph 6.4 (section 7(1)(d))", "source_url": "https://www.hasil.gov.my/wp-content/uploads/PR_11_2017.pdf", "source_type": "official-guidance", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": null, "reporting": [ { "title": "Declaring exempt foreign income", "text": "The LHDN guideline says taxpayers must keep documents showing foreign income was taxed abroad and declare in the income tax return form the type and amount of foreign income, the country where it arose and the foreign tax imposed. Check whether the 31 December 2026 end date has been extended in current guidance.", "source_url": "https://www.hasil.gov.my/wp-content/uploads/20240620-guidelines-tax-treatment-in-relation-to-income-received-from-abroad-amendment-june-2024.pdf" } ], "social_security": null, "living_base": "Foreign nationals live in Malaysia on passes and visas issued by the Immigration Department. Tax residence depends on physical presence under section 7, not on the pass held or on nationality.", "citizenship": "Malaysian citizenship is governed by the Federal Constitution and administered by the National Registration Department. Routes, residence periods and the position on dual citizenship are not stated here; check current official guidance.", "questions": [ "How many days was I in Malaysia in each basis year, counting part days as whole days?", "Do any of my absences count as temporary absences that link my periods of stay?", "Could I be resident this year under the 90-day route or the following-year route?", "Is my foreign income received in Malaysia covered by the exemption, and was it taxed in the country of origin?", "Has the foreign income exemption period been extended beyond 31 December 2026?", "How would a tax treaty tie-breaker apply if another country also treats me as resident?" ], "authorities": [ { "title": "Inland Revenue Board of Malaysia (LHDN)", "url": "https://www.hasil.gov.my/en/" }, { "title": "Immigration Department of Malaysia", "url": "https://www.imi.gov.my/" } ], "sources": [ { "title": "Public Ruling No. 11/2017: Residence Status of Individuals (LHDN, 22 December 2017)", "url": "https://www.hasil.gov.my/wp-content/uploads/PR_11_2017.pdf", "type": "official-guidance" }, { "title": "Guidelines: Tax Treatment in Relation to Income Received from Abroad (Amendment), 20 June 2024 (LHDN)", "url": "https://www.hasil.gov.my/wp-content/uploads/20240620-guidelines-tax-treatment-in-relation-to-income-received-from-abroad-amendment-june-2024.pdf", "type": "official-guidance" }, { "title": "Malaysia: Information on residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Malaysia-Residency.pdf", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "nl", "name": "Netherlands", "slug": "netherlands", "region": "Europe", "flag": "🇳🇱", "tax_year": "1 January to 31 December", "tax_basis": "residence", "summary": "Dutch law has no day count for individuals: under article 4 of the General State Taxes Act, where a person lives is judged on the circumstances. The tax administration looks at factors such as the address where most time is spent, where a partner or family lives, where the person works, has health insurance and a family doctor, and where children go to school.", "residence_rules": [ { "id": "NL-RES-01", "title": "Residence judged on the circumstances", "kind": "ties", "text": "Article 4(1) of the General State Taxes Act (AWR) provides that where a person lives is judged on the circumstances. To decide whether someone lives permanently in another country, the tax administration lists factors including the address where they spend most time, where a partner or family lives, where they work, have health insurance, a family doctor and memberships, and where children go to school. A holiday abroad is not emigration.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Am I emigrating if I am moving abroad?", "source_url": "https://www.belastingdienst.nl/wps/wcm/connect/en/individuals/content/moving-abroad-emigration", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "NL-RES-02", "title": "Return within one year", "kind": "presumption", "text": "Under article 2.2(1) of the Income Tax Act 2001, a person who stops living in the Netherlands and returns within a year without having lived in another state in the meantime is treated as having lived in the Netherlands during the absence. This does not apply where the person shows they were a resident taxpayer in an EU member state or a designated treaty state with information exchange, under the conditions in the article.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Wet inkomstenbelasting 2001, artikel 2.2", "source_url": "https://wetten.overheid.nl/BWBR0011353/2026-01-01#Hoofdstuk2_Afdeling2.1_Artikel2.2", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "NL-RES-03", "title": "Dutch nationals posted abroad by the State", "kind": "citizenship", "text": "A Dutch national employed by the Dutch State is always treated as living in the Netherlands when posted abroad as a member of a diplomatic, permanent or consular mission, or to carry out work under a treaty to which the Netherlands is party. Their partner and qualifying children can be treated the same way.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Wet inkomstenbelasting 2001, artikel 2.2", "source_url": "https://wetten.overheid.nl/BWBR0011353/2026-01-01#Hoofdstuk2_Afdeling2.1_Artikel2.2", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "For the year of emigration or immigration, the tax administration uses a specific return, filed online or on paper with form M, and has three years to issue a final assessment for that year. The one-year return rule (NL-RES-02) can treat a short absence as continued residence.", "reporting": [ { "title": "Return for the year of emigration or immigration (form M)", "text": "The return for a year in which a person moves to or from the Netherlands is filed online through Mijn Belastingdienst or on paper with form M.", "source_url": "https://www.belastingdienst.nl/wps/wcm/connect/en/individuals/content/partly-living-outside-the-netherlands-m-tax-return" }, { "title": "Expat Scheme (30% facility) decision", "text": "An employer-linked scheme for employees recruited from abroad with specific expertise, generally shown by a salary above a yearly threshold, who lived more than 150 km from the Dutch border for more than 16 of the 24 months before starting work. A decision lasts up to 5 years, shortened by earlier Dutch work or residence. Changes to the scheme from 2027 have been proposed, so check current guidance.", "source_url": "https://www.belastingdienst.nl/wps/wcm/connect/en/individuals/content/coming-to-work-in-the-netherlands-30-percent-facility" } ], "social_security": "Within the EU, a person is covered by one country's social security system at a time, and which one depends on work situation and residence, not nationality. Check the EU coordination rules and any bilateral agreement for work involving non-EU countries.", "living_base": "EU citizens can move to the Netherlands under EU free movement rules, with permanent residence after a continuous 5-year period of legal residence. Others generally need a residence permit from the Immigration and Naturalisation Service (IND). A residence permit does not decide where a person lives for tax purposes, which is judged on the circumstances.", "citizenship": "Naturalisation generally requires at least 5 consecutive years of living in the Kingdom of the Netherlands with a valid residence permit, with exceptions for some cases. The IND states that applicants must renounce their current nationality, with exemptions listed by the IND.", "questions": [ "Based on my home, family, work and other ties, where would I be considered to live for Dutch tax purposes?", "If I leave and return within a year, could the one-year rule treat me as having stayed resident?", "If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?", "Which parts of my year of arrival or departure go on the form M return?", "Do I meet the current Expat Scheme conditions, and how would proposed changes from 2027 affect a decision?", "Would any exemption from renouncing my current nationality apply if I naturalise?" ], "authorities": [ { "title": "Belastingdienst (Netherlands Tax Administration)", "url": "https://www.belastingdienst.nl" }, { "title": "Immigration and Naturalisation Service (IND)", "url": "https://ind.nl" } ], "sources": [ { "title": "Algemene wet inzake rijksbelastingen, artikel 4", "url": "https://wetten.overheid.nl/BWBR0002320/2026-01-01#HoofdstukI_Artikel4", "type": "primary-law" }, { "title": "Wet inkomstenbelasting 2001, artikel 2.2", "url": "https://wetten.overheid.nl/BWBR0011353/2026-01-01#Hoofdstuk2_Afdeling2.1_Artikel2.2", "type": "primary-law" }, { "title": "Am I emigrating if I am moving abroad?", "url": "https://www.belastingdienst.nl/wps/wcm/connect/en/individuals/content/moving-abroad-emigration", "type": "official-guidance" }, { "title": "Filing a tax return for the year of emigration or immigration", "url": "https://www.belastingdienst.nl/wps/wcm/connect/en/individuals/content/partly-living-outside-the-netherlands-m-tax-return", "type": "official-guidance" }, { "title": "Can I apply for the Expat Scheme (30% facility)?", "url": "https://www.belastingdienst.nl/wps/wcm/connect/en/individuals/content/coming-to-work-in-the-netherlands-30-percent-facility", "type": "official-guidance" }, { "title": "Becoming a Dutch national through naturalisation", "url": "https://ind.nl/en/dutch-citizenship/becoming-a-dutch-national-through-naturalisation", "type": "official-guidance" }, { "title": "Social security cover abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "nz", "name": "New Zealand", "slug": "new-zealand", "region": "Oceania", "flag": "🇳🇿", "tax_year": "1 April to 31 March", "tax_basis": "residence", "summary": "New Zealand treats a person as tax resident if they are present for more than 183 days in any 12-month period or have a permanent place of abode in New Zealand. Without a permanent place of abode, residence ends after more than 325 days away in any 12-month period, and from 1 April 2026 a non-resident visitor rule can keep some short-stay arrivals outside the 183-day rule.", "residence_rules": [ { "id": "NZ-RES-01", "title": "183-day rule", "kind": "day-count", "text": "You are tax resident if you have been in New Zealand for more than 183 days in any 12-month period, unless the person is a non-resident visitor or has become non-resident. Residence is backdated to the first of the 183 days. The days need not be consecutive, and part of a day counts as a whole day.", "threshold_days": 183, "window": "rolling-12-months", "day_method": "any-part", "source_title": "Inland Revenue IR292: New Zealand tax residence (April 2026)", "source_url": "https://www.ird.govt.nz/-/media/project/ir/home/documents/forms-and-guides/ir200---ir299/ir292/ir292-2026-april.pdf?modified=20260409012958", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "NZ-RES-02", "title": "Permanent place of abode", "kind": "ties", "text": "A person with a permanent place of abode in New Zealand is tax resident under the Income Tax Act 2007. This needs a dwelling where you habitually reside from time to time, judged on an overall assessment of your circumstances. The test overrides the day-count rules for absences.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Inland Revenue IR292: New Zealand tax residence (April 2026)", "source_url": "https://www.ird.govt.nz/-/media/project/ir/home/documents/forms-and-guides/ir200---ir299/ir292/ir292-2026-april.pdf?modified=20260409012958", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "NZ-RES-03", "title": "325-day rule for ceasing residence", "kind": "day-count", "text": "You become non-resident if you do not have a permanent place of abode in New Zealand and are away for more than 325 days in any 12-month period. The days need not be consecutive, and part of a day in New Zealand counts as a whole day.", "threshold_days": 325, "window": "rolling-12-months", "day_method": "any-part", "source_title": "Inland Revenue IR292: New Zealand tax residence (April 2026)", "source_url": "https://www.ird.govt.nz/-/media/project/ir/home/documents/forms-and-guides/ir200---ir299/ir292/ir292-2026-april.pdf?modified=20260409012958", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "NZ-RES-04", "title": "Non-resident visitor rule", "kind": "day-count", "text": "A person who arrived on or after 1 April 2026, is present 275 days or fewer in any 18-month period and meets conditions (for example not working for a New Zealand resident, not selling to New Zealand customers, lawfully present, and taxed where resident) is not subject to the 183-day rule. A person who stays more than 275 days and is lawfully present becomes resident from day 276.", "threshold_days": 275, "window": null, "day_method": null, "source_title": "Inland Revenue IR292: New Zealand tax residence (April 2026)", "source_url": "https://www.ird.govt.nz/-/media/project/ir/home/documents/forms-and-guides/ir200---ir299/ir292/ir292-2026-april.pdf?modified=20260409012958", "source_type": "official-guidance", "effective": "Arrivals on or after 1 April 2026", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Relates to NZ-RES-01 and NZ-RES-03. Both day-count rules are backdated, so they can overlap for people who travel in and out. New migrants and returning New Zealanders who were not tax resident in the previous 10 years may receive a one-off temporary exemption on most foreign income, ending 48 months after the month they qualify as resident, unless it ends earlier under Inland Revenue's rules.", "reporting": [ { "title": "Individual tax return (IR3) for worldwide income", "text": "Inland Revenue says New Zealand tax residents are taxed on worldwide income and must state income from all sources, including overseas, in an Individual tax return (IR3), apportioning overseas income to the New Zealand tax year where needed.", "source_url": "https://www.ird.govt.nz/-/media/project/ir/home/documents/forms-and-guides/ir200---ir299/ir292/ir292-2026-april.pdf?modified=20260409012958" } ], "social_security": null, "living_base": "The right to live in New Zealand comes from visas granted by Immigration New Zealand. Tax residence is decided by Inland Revenue's day-count and permanent place of abode tests, not by the visa held.", "citizenship": "New Zealand citizenship by grant is administered by the Department of Internal Affairs and includes a presence requirement. The exact presence figures and the position on dual citizenship are not stated here; check the Department's current guidance.", "questions": [ "Do I have a permanent place of abode in New Zealand, given how I use any home there?", "From which date would the 183-day rule backdate my residence?", "If I arrived after 1 April 2026, do I meet every condition of the non-resident visitor rule?", "If I leave, have I been away more than 325 days in a 12-month period, and do I still have a permanent place of abode?", "Do I qualify for the temporary tax exemption on foreign income, and which income types does it exclude?", "How would a tax treaty tie-breaker apply if another country also treats me as resident?" ], "authorities": [ { "title": "Inland Revenue", "url": "https://www.ird.govt.nz/" }, { "title": "Immigration New Zealand", "url": "https://www.immigration.govt.nz/" }, { "title": "Department of Internal Affairs (citizenship)", "url": "https://www.dia.govt.nz/" } ], "sources": [ { "title": "New Zealand tax residence: Who is a New Zealand resident for tax purposes? IR292 (April 2026)", "url": "https://www.ird.govt.nz/-/media/project/ir/home/documents/forms-and-guides/ir200---ir299/ir292/ir292-2026-april.pdf?modified=20260409012958", "type": "official-guidance" }, { "title": "Temporary tax exemption (Inland Revenue)", "url": "https://www.ird.govt.nz/roles/nz-tax-residents/exemption", "type": "official-guidance" }, { "title": "Interpretation Statement IS 16/03: Tax Residence (Inland Revenue, 20 September 2016)", "url": "https://www.taxtechnical.ird.govt.nz/-/media/project/ir/tt/pdfs/interpretation-statements/is-1603.pdf?modified=20200316215945&modified=20200316215945", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "pa", "name": "Panama", "slug": "panama", "region": "Central America", "flag": "🇵🇦", "tax_year": "Check current DGI guidance", "tax_basis": "territorial", "summary": "Panama's income tax is built on a territoriality principle: it taxes income produced within Panama, and its legislation refers to this as the principle of territoriality in the Panamanian legal framework. From the 2027 fiscal period, Law 526 of 2026 makes an exception for entities in multinational groups, which must show economic substance in Panama or pay a 15% rate on certain foreign-source passive income.", "residence_rules": [ { "id": "PA-RES-01", "title": "Treaty residence and tie-breaker", "kind": "ties", "text": "In Panama's treaty with Mexico, a resident is a person liable to tax in a state because of domicile, residence, place of management or similar criteria; the term excludes persons taxed there only on income from sources in that state. A person resident in both states is resident where they have a permanent home available, and if that does not decide, where their personal and economic relations are closer (centre of vital interests), followed by further tests. Other treaties must be read on their own terms.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Convenio Panamá–México para evitar la doble imposición, artículo 4 (Ley 24 de 31 de marzo de 2010)", "source_url": "https://dgi.mef.gob.pa/Internacional/CONVENIOS/Mexico/Ley%2024%20de%2031%20de%20marzo%20de%202010%20Panam%C3%A1_M%C3%A9xico.pdf", "source_type": "treaty", "effective": null, "checked": "2026-11-08" }, { "id": "PA-RES-02", "title": "Permanent establishment of foreign-domiciled persons: 183-day thresholds", "kind": "day-count", "text": "Article 762-M of the Fiscal Code, as rewritten by Law 526 of 2026, treats foreign-domiciled persons as operating through a permanent establishment when they have a fixed place of business in Panama, and also when construction or installation work, or services by staff present in Panama, last more than 183 days within any twelve-month period. A permanent establishment is taxed on the Panamanian-source income attributable to it. This is a business-presence rule, not a test of individual tax residence.", "threshold_days": 183, "window": "rolling-12-months", "day_method": null, "source_title": "Ley 526 de 28 de mayo de 2026, artículo 3 (Gaceta Oficial 30534-B)", "source_url": "https://s3-legispan.asamblea.gob.pa/legispan/GACETAS/2020/2026/30534-B_2026.pdf", "source_type": "primary-law", "effective": "From the 2027 fiscal period", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": null, "reporting": [ { "title": "Foreign-source passive income and substance information (multinational group entities)", "text": "From the 2027 fiscal period, entities that belong to a multinational group and earn foreign-source dividends, interest, royalties, capital gains or real estate and other capital income must report that income and the information showing economic substance in Panama in their annual income tax return. Entities that do not show substance are taxed at a single 15% rate on the net foreign passive income.", "source_url": "https://s3-legispan.asamblea.gob.pa/legispan/GACETAS/2020/2026/30534-B_2026.pdf" } ], "social_security": null, "living_base": "Foreign nationals need a migration permit or residence from the Servicio Nacional de Migración to live in Panama. The specific residence categories were not verified from an official page for this record. A residence permit does not by itself decide tax residence or how foreign income is treated.", "citizenship": "Routes to Panamanian nationality, including naturalization residence periods and any rules on keeping another nationality, were not verified from an official page for this record; check the Constitution and the current requirements of the competent authorities.", "questions": [ "Which of my income items would count as produced within Panama, and which as foreign-source?", "Do I need a Panamanian tax residence certificate for treaty purposes, and on what criteria would it be issued?", "How would a treaty tie-breaker apply if another country also treats me as resident?", "If I own or manage a company in a multinational group, how would Law 526 of 2026 affect its foreign passive income from 2027?", "What economic substance would a Panamanian entity need to show, and what records must it keep?", "Could my activity in Panama, or my employer's, create a permanent establishment under the 183-day thresholds?", "Does my migration category carry any tax filing or reporting duty?" ], "authorities": [ { "title": "Dirección General de Ingresos (DGI), Ministerio de Economía y Finanzas", "url": "https://dgi.mef.gob.pa" }, { "title": "Servicio Nacional de Migración", "url": "https://www.migracion.gob.pa" } ], "sources": [ { "title": "Gaceta Oficial 30534-B, Ley 526 de 28 de mayo de 2026 (sustancia económica para rentas pasivas de fuente extranjera)", "url": "https://s3-legispan.asamblea.gob.pa/legispan/GACETAS/2020/2026/30534-B_2026.pdf", "type": "primary-law" }, { "title": "Convenio entre Panamá y México para evitar la doble imposición (Ley 24 de 31 de marzo de 2010), DGI", "url": "https://dgi.mef.gob.pa/Internacional/CONVENIOS/Mexico/Ley%2024%20de%2031%20de%20marzo%20de%202010%20Panam%C3%A1_M%C3%A9xico.pdf", "type": "treaty" }, { "title": "Dirección General de Ingresos – Leyes, Decretos y Resoluciones", "url": "https://dgi.mef.gob.pa/L-Fiscal/L-Fiscal.php", "type": "official-guidance" }, { "title": "Servicio Nacional de Migración – Panamá", "url": "https://www.migracion.gob.pa/", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "pl", "name": "Poland", "slug": "poland", "region": "Europe", "flag": "🇵🇱", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "residence", "summary": "Poland treats an individual as tax resident if their centre of personal or economic interests (centre of vital interests) is in Poland, or if they stay in Poland for more than 183 days in a tax year. Either test is enough on its own, and Ministry of Finance guidance counts any part of a day spent in Poland as a day of presence.", "residence_rules": [ { "id": "PL-RES-01", "title": "Centre of vital interests in Poland", "kind": "ties", "text": "Under Article 3(1a) of the Personal Income Tax Act, a person whose centre of personal interests or centre of economic interests is in Poland is resident. Ministry of Finance guidance describes this as having close personal or economic ties with Poland, assessed on the person's own circumstances. This test can apply even when the person spends fewer than 183 days in Poland.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Objaśnienia podatkowe z dnia 29 kwietnia 2021 r.: Rezydencja podatkowa oraz zakres obowiązku podatkowego osób fizycznych w Polsce", "source_url": "https://www.gov.pl/attachment/8f2d0cf1-ee3c-49a4-ae8e-e41c4fb19df7", "source_type": "official-guidance", "effective": "Personal Income Tax Act of 26 July 1991, Article 3(1a); guidance of 29 April 2021", "checked": "2026-11-08" }, { "id": "PL-RES-02", "title": "More than 183 days in the tax year", "kind": "day-count", "text": "A person who stays in Poland for more than 183 days in a tax year is resident. The stay does not need to be continuous, and the count is made separately for each calendar year. Ministry of Finance guidance uses a physical presence method: any part of a day in Poland, including the day of arrival or departure, counts as a day, while full days spent outside Poland do not.", "threshold_days": 183, "window": "tax-year", "day_method": "any-part", "source_title": "Objaśnienia podatkowe z dnia 29 kwietnia 2021 r.: Rezydencja podatkowa oraz zakres obowiązku podatkowego osób fizycznych w Polsce", "source_url": "https://www.gov.pl/attachment/8f2d0cf1-ee3c-49a4-ae8e-e41c4fb19df7", "source_type": "official-guidance", "effective": "Personal Income Tax Act of 26 July 1991, Article 3(1a); guidance of 29 April 2021", "checked": "2026-11-08" }, { "id": "PL-RES-03", "title": "Tax treaties apply alongside domestic rules", "kind": "ties", "text": "The domestic residence rules are applied together with the double taxation agreements Poland is party to (Article 4a of the Personal Income Tax Act). Where a person is resident in Poland and another country under domestic law, the treaty's residence article decides which country treats them as resident for treaty purposes.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Poland - Information on residency for tax purposes (OECD AEOI portal)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Poland-Tax-Residency.pdf", "source_type": "official-guidance", "effective": "Personal Income Tax Act, Articles 3(1a) and 4a", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Residence can change during the tax year. Ministry of Finance guidance says a person is taxed on worldwide income up to the day they stop being Polish resident, and after moving their residence abroad only on income earned in Poland (PL-RES-01).", "reporting": [], "social_security": "Poland applies the EU rules on social security coordination: a person is generally covered by one country's system at a time, and a PD A1 form can show continued home-country cover during a temporary posting. Check national contribution rules with the Polish social insurance institution.", "living_base": "EU citizens can stay in Poland for up to three months without registering and may need to register for longer stays; after five years of continuous lawful residence they acquire the right of permanent residence. Non-EU nationals generally need a national visa or residence permit under Polish rules; the Office for Foreigners is the central immigration authority. A permit or registration does not by itself decide tax residence; the tests above do.", "citizenship": "Polish citizenship is acquired mainly by descent or by naturalization after a period of lawful residence, with other routes set by national law. This record has not verified the current residence period or the position on dual citizenship; check the competent Polish authority's current guidance.", "questions": [ "Where is my centre of personal interests and where is my centre of economic interests, and do they point to the same country?", "How many days, counting any part of a day, have I spent in Poland in each calendar year?", "On what date did my residence change if I moved to or from Poland during the year?", "Does another country also treat me as tax resident, and how does the tax treaty with Poland decide my residence?", "Which of my income counts as earned in Poland if I am not Polish resident for part of the year?", "What certificate of residence from another country, if any, will Polish payers or the tax office ask me for?" ], "authorities": [ { "title": "Ministry of Finance tax portal (podatki.gov.pl)", "url": "https://www.podatki.gov.pl/" }, { "title": "Office for Foreigners", "url": "https://www.gov.pl/web/udsc-en" } ], "sources": [ { "title": "Objaśnienia podatkowe z dnia 29 kwietnia 2021 r.: Rezydencja podatkowa oraz zakres obowiązku podatkowego osób fizycznych w Polsce", "url": "https://www.gov.pl/attachment/8f2d0cf1-ee3c-49a4-ae8e-e41c4fb19df7", "type": "official-guidance" }, { "title": "Objaśnienia podatkowe z 29 kwietnia 2021 r. ws. rezydencji podatkowej - Ministerstwo Finansów", "url": "https://www.gov.pl/web/finanse/objasnienia-podatkowe-z-29-kwietnia-2021-r-ws-rezydencji-podatkowej-oraz-zakresu-obowiazku-podatkowego-osob-fizycznych-w-polsce", "type": "official-guidance" }, { "title": "Poland - Information on residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Poland-Tax-Residency.pdf", "type": "official-guidance" }, { "title": "Social security cover when you live or work in another EU country - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights when living abroad in the EU - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "pt", "name": "Portugal", "slug": "portugal", "region": "Europe", "flag": "🇵🇹", "tax_year": "1 January to 31 December", "tax_basis": "residence", "summary": "Portugal treats a person as resident if they stay more than 183 days in any 12-month period that starts or ends in the tax year, or if on any day of that period they have a home in conditions suggesting an intention to keep it as a habitual residence. The non-habitual resident (NHR) rules were revoked by Lei n.º 82/2023 with transitional rules for some existing taxpayers, and a separate regime (IFICI, article 58.º-A of the Tax Benefits Statute) applies a special rate to some income from listed activities for people not resident in the five prior years.", "residence_rules": [ { "id": "PT-RES-01", "title": "More than 183 days in any 12-month period", "kind": "day-count", "text": "A person is resident if they stayed in Portugal more than 183 days, consecutive or not, in any 12-month period that starts or ends in the tax year. A day counts if it includes an overnight stay in Portugal, even if only part of the day is spent there.", "threshold_days": 183, "window": "rolling-12-months", "day_method": "official-guidance", "source_title": "Artigo 16.º Residência (Código do IRS)", "source_url": "https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/irs16.aspx", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "PT-RES-02", "title": "Home kept as a habitual residence", "kind": "ties", "text": "A person who stayed for fewer days can still be resident if, on any day of the same 12-month period, they have housing in Portugal in conditions suggesting a current intention to keep and occupy it as their habitual residence. This test does not depend on a day count.", "threshold_days": null, "window": "rolling-12-months", "day_method": null, "source_title": "Artigo 16.º Residência (Código do IRS)", "source_url": "https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/irs16.aspx", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Under article 16.º of the IRS Code, a person who meets PT-RES-01 or PT-RES-02 becomes resident from the first day of presence in Portugal, unless they were resident on any day of the previous year, in which case residence runs from 1 January. Residence ends on the last day of presence, except in listed cases such as a person who stays more than 183 days in the year of departure and earns income after leaving that would be taxable in Portugal, who is treated as resident for the whole year.", "reporting": [ { "title": "IFICI registration", "text": "The IFICI regime applies a special 20% rate to net employment and business income from listed activities for up to 10 consecutive years, for people who become resident and were not resident in the five prior years; people who benefited from NHR are excluded. Registration is set by ministerial ordinance, and late registration means the rate applies only from the year of registration for the remaining period.", "source_url": "https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/bf_rep/Pages/ebf58A.aspx" } ], "social_security": "Within the EU, a person is covered by one country's social security system at a time, and which one depends on work situation and residence, not nationality. Check the EU coordination rules and any bilateral agreement for work involving non-EU countries.", "living_base": "EU citizens can move to Portugal under EU free movement rules, with permanent residence after a continuous 5-year period of legal residence. Others generally need a visa and a residence permit through the immigration authority. A residence permit does not decide tax residence, which follows article 16.º of the IRS Code.", "citizenship": "Since Lei Orgânica n.º 1/2026 (published 18 May 2026, in force the next day), naturalisation by residence requires at least seven years of legal residence for nationals of Portuguese-speaking countries and EU citizens, and 10 years for other nationals, among other conditions; pending procedures at the date of entry into force follow the previous law. A person married for more than three years to a Portuguese national can acquire nationality by declaration. The Nationality Law addresses people with two or more nationalities, one of them Portuguese, and provides that only the Portuguese one is relevant under Portuguese law.", "questions": [ "How should my days in Portugal be counted for each 12-month period that starts or ends in the tax year?", "Could a home I keep in Portugal be treated as a habitual residence even if I spend fewer days there?", "On which day would my residence start or end, and does the whole-year exception for departure years apply to me?", "Does any transitional NHR rule still apply to my situation, or does it not apply at all?", "Do my activity and past residence history meet the IFICI conditions, and how is foreign-source income treated under it?", "If another country also treats me as resident, how does the relevant tax treaty tie-breaker apply?", "How do the 2026 nationality rules count my years of legal residence?" ], "authorities": [ { "title": "Autoridade Tributária e Aduaneira (Portal das Finanças)", "url": "https://info.portaldasfinancas.gov.pt" }, { "title": "Agência para a Integração, Migrações e Asilo (AIMA)", "url": "https://aima.gov.pt" }, { "title": "Instituto dos Registos e do Notariado (nationality)", "url": "https://irn.justica.gov.pt" } ], "sources": [ { "title": "Artigo 16.º Residência (Código do IRS)", "url": "https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/irs16.aspx", "type": "primary-law" }, { "title": "Artigo 58.º-A – Incentivo fiscal à investigação científica e inovação (Estatuto dos Benefícios Fiscais)", "url": "https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/bf_rep/Pages/ebf58A.aspx", "type": "primary-law" }, { "title": "Lei Orgânica n.º 1/2026, de 18 de maio (Diário da República, 1.ª série, n.º 95)", "url": "https://www.madeira.gov.pt//Portals/25/Documentos/Legislacao/Lei_Organica_1_2026.pdf", "type": "primary-law" }, { "title": "Social security cover abroad - Your Europe", "url": "https://europa.eu/youreurope/citizens/work/unemployment-and-benefits/country-coverage/index_en.htm", "type": "official-guidance" }, { "title": "Residence rights - Your Europe", "url": "https://europa.eu/youreurope/citizens/residence/residence-rights/index_en.htm", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "sg", "name": "Singapore", "slug": "singapore", "region": "Asia", "flag": "🇸🇬", "tax_year": "Calendar year of income, assessed in the following Year of Assessment (preceding year basis)", "tax_basis": "territorial", "summary": "Singapore taxes income earned in Singapore. IRAS treats citizens and permanent residents who normally reside in Singapore as residents, and foreigners as residents when they stay or work there at least 183 days in the calendar year, with two- and three-year administrative concessions. IRAS states that foreign-sourced income received in Singapore by residents is generally exempt, except income received through Singapore partnerships.", "residence_rules": [ { "id": "SG-RES-01", "title": "Citizens and permanent residents who normally reside", "kind": "ties", "text": "A Singapore Citizen or Singapore Permanent Resident who normally resides in Singapore, except for temporary absences, is treated as a tax resident.", "threshold_days": null, "window": null, "day_method": null, "source_title": "IRAS: Working out my tax residency", "source_url": "https://www.iras.gov.sg/taxes/individual-income-tax/basics-of-individual-income-tax/tax-residency-and-tax-rates/working-out-my-tax-residency", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "SG-RES-02", "title": "183-day test for foreigners", "kind": "day-count", "text": "A foreigner who stayed or worked in Singapore for at least 183 days in the previous calendar year is a tax resident for that Year of Assessment. IRAS says days of employment include weekends and public holidays, and temporary absences incidental to the job still count. Foreigners with a work pass valid for at least one year are also treated as residents, but status is reviewed at tax clearance.", "threshold_days": 183, "window": "calendar-year", "day_method": "official-guidance", "source_title": "IRAS: Working out my tax residency", "source_url": "https://www.iras.gov.sg/taxes/individual-income-tax/basics-of-individual-income-tax/tax-residency-and-tax-rates/working-out-my-tax-residency", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "SG-RES-03", "title": "Two-year administrative concession", "kind": "day-count", "text": "Where employment straddles two calendar years, a foreigner may be treated as resident for both years if the employment period plus physical presence immediately before and after it covers a continuous period of at least 183 days. IRAS excludes company directors, public entertainers and professionals from this concession.", "threshold_days": 183, "window": "multi-year", "day_method": "official-guidance", "source_title": "IRAS: Working out my tax residency", "source_url": "https://www.iras.gov.sg/taxes/individual-income-tax/basics-of-individual-income-tax/tax-residency-and-tax-rates/working-out-my-tax-residency", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "SG-RES-04", "title": "Three-year administrative concession", "kind": "presumption", "text": "A foreigner who stays or works in Singapore continuously for three consecutive years is treated as resident for all three years, even if presence is under 183 days in the first and third years.", "threshold_days": null, "window": "multi-year", "day_method": null, "source_title": "IRAS: Working out my tax residency", "source_url": "https://www.iras.gov.sg/taxes/individual-income-tax/basics-of-individual-income-tax/tax-residency-and-tax-rates/working-out-my-tax-residency", "source_type": "official-guidance", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Relates to SG-RES-02. When a non-citizen employee stops working, is posted overseas or leaves Singapore for more than three months, the employer must file Form IR21 at least one month before the last day and withhold monies due until IRAS clears the tax. IRAS may review residency at that point.", "reporting": [ { "title": "Tax clearance (Form IR21)", "text": "Employers file Form IR21 for non-Singapore-citizen employees who cease employment, are posted overseas or leave for more than three months, and withhold payments due to the employee from the date they learn of the departure.", "source_url": "https://www.iras.gov.sg/taxes/individual-income-tax/employees/scenario-based-faqs-for-working-in-singapore-and-abroad/tax-clearance-for-non-singapore-citizen-employees" } ], "social_security": null, "living_base": "Foreigners usually live in Singapore on a work pass from the Ministry of Manpower or with permanent residence from the Immigration and Checkpoints Authority. IRAS links some residency treatment to work pass length, but it reviews actual presence at tax clearance, so a pass does not settle tax residence.", "citizenship": "Singapore citizenship is administered by the Immigration and Checkpoints Authority. Routes, residence periods and the position on dual citizenship are not stated here; check the Authority's current guidance.", "questions": [ "How many days did I stay or work in Singapore in each calendar year, and which days count?", "Does the two-year or three-year concession apply to my pattern of work and travel?", "Is any of my overseas income taxable in Singapore because it is incidental to Singapore employment or received through a partnership?", "If I work wholly outside Singapore, is any of my employment income sourced in Singapore?", "What happens at tax clearance if I leave before meeting 183 days?", "How would a tax treaty tie-breaker apply if another country also treats me as resident?" ], "authorities": [ { "title": "Inland Revenue Authority of Singapore (IRAS)", "url": "https://www.iras.gov.sg/" }, { "title": "Immigration and Checkpoints Authority (ICA)", "url": "https://www.ica.gov.sg/" }, { "title": "Ministry of Manpower (MOM)", "url": "https://www.mom.gov.sg/" } ], "sources": [ { "title": "Working out my tax residency (IRAS)", "url": "https://www.iras.gov.sg/taxes/individual-income-tax/basics-of-individual-income-tax/tax-residency-and-tax-rates/working-out-my-tax-residency", "type": "official-guidance" }, { "title": "Tax clearance for non-Singapore citizen employees (IRAS)", "url": "https://www.iras.gov.sg/taxes/individual-income-tax/employees/scenario-based-faqs-for-working-in-singapore-and-abroad/tax-clearance-for-non-singapore-citizen-employees", "type": "official-guidance" }, { "title": "I want to know the tax treatment on working outside Singapore (IRAS)", "url": "https://www.iras.gov.sg/taxes/individual-income-tax/employees/scenario-based-faqs-for-working-in-singapore-and-abroad/i-want-to-know-the-tax-treatment-on-working-outside-singapore", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "th", "name": "Thailand", "slug": "thailand", "region": "Asia", "flag": "🇹🇭", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "remittance-available", "summary": "Thailand treats a person as resident on a calendar-year day count of 180 days, regardless of nationality. Residents are taxed on Thai-source income and on foreign income brought into Thailand; since 1 January 2024, Revenue Department Order Por. 161/2566 taxes foreign income earned from 2024 onward in the year it is brought in, whichever year that is.", "residence_rules": [ { "id": "TH-RES-01", "title": "180-day residence test", "kind": "day-count", "text": "A person who is in Thailand for one or more periods totalling 180 days in a tax (calendar) year is treated as resident, whether the stay is continuous or broken and regardless of nationality. The Revenue Department Q&A words this as 180 days or more, while its English summary says more than 180 days, so check the current official text. A non-resident is taxed only on Thai-source income.", "threshold_days": 180, "window": "calendar-year", "day_method": null, "source_title": "Q&A on personal income tax under section 41 paragraph 2 of the Revenue Code (Revenue Department, Legal Affairs Division, Thai)", "source_url": "https://www.rd.go.th/fileadmin/download/news/question_p161_162.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "TH-RES-02", "title": "Foreign income brought into Thailand (Por. 161/2566)", "kind": "day-count", "text": "A resident who has foreign-source income from work, business or property must include it in the tax year it is brought into Thailand, whichever year that is. The Revenue Department Q&A says this applies to foreign income arising from 1 January 2024 in a tax year in which the person was in Thailand 180 days or more, brought in that year or later. Income arising before 1 January 2024 is excluded under the amendment in Order Por. 162/2566.", "threshold_days": 180, "window": "calendar-year", "day_method": null, "source_title": "Revenue Department Order No. Por. 161/2566 on tax under section 41 paragraph 2 of the Revenue Code, as amended by Por. 162/2566 (Thai)", "source_url": "https://www.rd.go.th/fileadmin/user_upload/kormor/newlaw/dn161A.pdf", "source_type": "official-guidance", "effective": "Income brought into Thailand from 1 January 2024", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": null, "reporting": [ { "title": "Annual personal income tax return", "text": "A person liable to personal income tax computes the liability, files a return and pays any tax on a calendar-year basis.", "source_url": "https://www.rd.go.th/english/6045.html" } ], "social_security": null, "living_base": "People usually live in Thailand under a visa and permission to stay granted by the Immigration Bureau, with work permits handled separately. A visa does not decide tax residence; the Revenue Department counts days present in the calendar year.", "citizenship": "Thai nationality is governed by the Nationality Act. Routes, residence periods and the position on dual nationality are not stated here; check the Ministry of Interior and current official guidance.", "questions": [ "How many days was I in Thailand in each calendar year, and how are arrival and departure days counted?", "Which of my foreign income arose before 1 January 2024, and what records show when it was earned?", "If I bring foreign income into Thailand in a later year, which year's day count matters?", "Does transferring savings or capital, rather than income, into Thailand create assessable income in my case?", "How would a foreign tax credit or a tax treaty apply to foreign income I bring in?", "Do I need a Thai tax identification number and an annual return?" ], "authorities": [ { "title": "The Revenue Department", "url": "https://www.rd.go.th/english/" }, { "title": "Immigration Bureau", "url": "https://www.immigration.go.th/" } ], "sources": [ { "title": "Personal Income Tax (Revenue Department English site)", "url": "https://www.rd.go.th/english/6045.html", "type": "official-guidance" }, { "title": "Revenue Department Order No. Por. 161/2566 (Thai)", "url": "https://www.rd.go.th/fileadmin/user_upload/kormor/newlaw/dn161A.pdf", "type": "official-guidance" }, { "title": "Q&A on personal income tax under section 41 paragraph 2 of the Revenue Code (Thai)", "url": "https://www.rd.go.th/fileadmin/download/news/question_p161_162.pdf", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "tr", "name": "Türkiye", "slug": "turkiye", "region": "Europe", "flag": "🇹🇷", "tax_year": "Calendar year (1 January to 31 December)", "tax_basis": "residence", "summary": "Türkiye treats an individual as settled, and so taxed on income from Türkiye and abroad, if their domicile is in Türkiye or they stay there continuously for more than six months in a calendar year, with temporary absences not breaking the stay. Some foreigners present for a set mission, study, treatment, rest or travel are not treated as settled even after six months, and a 2026 law added an exemption for the foreign-source income of some new residents for 20 years, subject to conditions and an exemption certificate.", "residence_rules": [ { "id": "TR-RES-01", "title": "Domicile in Türkiye", "kind": "ties", "text": "Under Article 4 of the Income Tax Law No. 193, a person whose domicile (ikametgâh) is in Türkiye is treated as settled in Türkiye. Article 3 taxes settled persons on their full income earned inside and outside Türkiye. Where another country also treats the person as resident, the tax treaty's tie-breaker tests apply.", "threshold_days": null, "window": null, "day_method": null, "source_title": "GİB özelge 62030549-120[65-2014/590]-92674 (9 November 2015)", "source_url": "https://cdn.gib.gov.tr/api/gibportal-file/file/getFileResources?objectKey=arsiv%2Fmevzuat%2Fuluslararasi_mevzuat%2FOZEL_92674.html", "source_type": "official-guidance", "effective": "Income Tax Law No. 193, Articles 3 and 4", "checked": "2026-11-08" }, { "id": "TR-RES-02", "title": "Continuous stay of more than six months in a calendar year", "kind": "day-count", "text": "A person who stays in Türkiye continuously for more than six months in one calendar year is treated as settled in Türkiye. Temporary absences do not interrupt the continuity of the stay. The law states this test in months, not days.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "Türkiye - Information on residency for tax purposes (OECD AEOI portal)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Turkiye-Tax-Residency.pdf", "source_type": "official-guidance", "effective": "Income Tax Law No. 193, Article 4", "checked": "2026-11-08" }, { "id": "TR-RES-03", "title": "Foreigners not treated as settled despite a long stay", "kind": "presumption", "text": "Under Article 5, some foreigners are not treated as settled even if they stay more than six months. These include businesspeople, scientists, specialists, officials and press correspondents who come for a set or temporary mission or for business, people who come for study, medical treatment, rest or travel, and people who stay for reasons beyond their control such as detention or illness.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "Türkiye - Information on residency for tax purposes (OECD AEOI portal)", "source_url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Turkiye-Tax-Residency.pdf", "source_type": "official-guidance", "effective": "Income Tax Law No. 193, Article 5", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": null, "reporting": [ { "title": "Exemption certificate for foreign-source income (Article 20/D)", "text": "Article 20/D of the Income Tax Law, added by Law No. 7582 of 21 May 2026, exempts the foreign-source income of a person who becomes settled in Türkiye from 1 January 2026 for 20 years, if they had no domicile and no tax liability in Türkiye in the three calendar years before. The person applies to the competent tax office for the exemption certificate by the end of the calendar year in which they become settled, or by the end of the second month of the next year if they become settled in the last two months. GİB guidance also sets a 1% inheritance tax rate for transfers by inheritance during the 20-year period.", "source_url": "https://cdn.gib.gov.tr/api/gibportal-file/file/getFile?objectKey=DUYURU%2FUNIVERSAL%2F2026%2F2026_Yurt_Disindan_Elde_Edilen_Kazanclarda_Vergi_Istisnasi_Rehberi.pdf" } ], "social_security": null, "living_base": "Foreign nationals generally need a visa or residence permit under Türkiye's migration rules, administered by the Presidency of Migration Management. A residence permit does not by itself decide tax residence; the domicile and six-month tests do, and Article 5 keeps some foreigners whose stay has a temporary purpose outside the settled category.", "citizenship": "Turkish citizenship is acquired mainly by descent or by naturalization after a period of lawful residence, with other routes set by national law. This record has not verified the current residence period or the position on dual citizenship; check the competent Turkish authority's current guidance.", "questions": [ "Is my domicile (ikametgâh) in Türkiye for the purposes of Article 4 of the Income Tax Law?", "Have I stayed in Türkiye continuously for more than six months in the calendar year, and which of my absences count as temporary?", "Does any Article 5 exception, such as a set mission, study, treatment or travel, apply to my stay?", "Do I meet the Article 20/D conditions, including no domicile and no tax liability in Türkiye in the three prior calendar years, and by what date must I apply for the exemption certificate?", "Which of my income counts as foreign-source income, and how are related costs and Turkish-source income treated?", "Does another country also treat me as tax resident, and how does the tax treaty with Türkiye decide my residence?" ], "authorities": [ { "title": "Revenue Administration (Gelir İdaresi Başkanlığı, GİB)", "url": "https://www.gib.gov.tr/" }, { "title": "Presidency of Migration Management", "url": "https://en.goc.gov.tr/" } ], "sources": [ { "title": "Türkiye - Information on residency for tax purposes (OECD AEOI portal)", "url": "https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Turkiye-Tax-Residency.pdf", "type": "official-guidance" }, { "title": "Yurt Dışından Elde Edilen Kazanç ve İratlarda Vergi İstisnası (Gelir Vergisi Kanunu Mükerrer Madde 20/D) - GİB rehberi", "url": "https://cdn.gib.gov.tr/api/gibportal-file/file/getFile?objectKey=DUYURU%2FUNIVERSAL%2F2026%2F2026_Yurt_Disindan_Elde_Edilen_Kazanclarda_Vergi_Istisnasi_Rehberi.pdf", "type": "official-guidance" }, { "title": "GİB özelge 62030549-120[65-2014/590]-92674 (9 November 2015)", "url": "https://cdn.gib.gov.tr/api/gibportal-file/file/getFileResources?objectKey=arsiv%2Fmevzuat%2Fuluslararasi_mevzuat%2FOZEL_92674.html", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "us", "name": "United States", "slug": "united-states", "region": "North America", "flag": "🇺🇸", "tax_year": "Calendar year (January 1 to December 31)", "tax_basis": "citizenship-and-residence", "summary": "The United States taxes its citizens and resident aliens on worldwide income wherever they live, and a non-citizen becomes a US tax resident by meeting either the green card test or the substantial presence test for the calendar year. Moving abroad does not by itself end US tax filing duties for a citizen or green card holder.", "residence_rules": [ { "id": "US-RES-01", "title": "Citizenship-based taxation: citizens and resident aliens abroad", "kind": "citizenship", "text": "IRS guidance says US citizens and resident aliens are subject to tax on worldwide income from all sources. Filing rules for income, estate and gift tax returns and estimated tax are generally the same whether the person lives in the United States or abroad. Living abroad changes which exclusions, credits and treaty rules may apply, not whether the person is a US taxpayer.", "threshold_days": null, "window": null, "day_method": null, "source_title": "IRS: U.S. citizens and resident aliens abroad", "source_url": "https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-resident-aliens-abroad", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "US-RES-02", "title": "Green card test", "kind": "registration", "text": "A person is a US tax resident under this test if they are a lawful permanent resident of the United States at any time during the calendar year. IRS guidance says the status continues unless it is voluntarily given up in writing to USCIS, or is administratively or judicially terminated. Day counts do not matter for this test.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "IRS: U.S. tax residency – Green card test", "source_url": "https://www.irs.gov/individuals/international-taxpayers/alien-residency-green-card-test", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "US-RES-03", "title": "Substantial presence test: 31 days and a weighted 183-day count", "kind": "day-count", "text": "A person meets the test if they are physically present in the United States on at least 31 days in the current year and on at least 183 days over a three-year period, counting all days in the current year, one third of the days in the first preceding year and one sixth of the days in the second preceding year. Any part of a day counts as a day of presence. Some days are excluded, such as certain commuting days from Canada or Mexico, transit of under 24 hours, and days as an exempt individual (for example certain students, teachers and trainees on F, J, M or Q visas who substantially comply with their visa).", "threshold_days": 183, "window": "multi-year", "day_method": "any-part", "source_title": "IRS: Substantial presence test", "source_url": "https://www.irs.gov/individuals/international-taxpayers/substantial-presence-test", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" }, { "id": "US-RES-04", "title": "Closer connection exception to the substantial presence test", "kind": "ties", "text": "A person who meets the substantial presence test may still be treated as not resident if, for the year, they were present in the United States on fewer than 183 days, kept a tax home in one foreign country for the entire year, and had a closer connection to that country than to the United States. The exception is not available to anyone who took steps toward, or had an application pending for, a green card during the year. The claim is made on Form 8840.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "IRS: Closer connection exception to the substantial presence test", "source_url": "https://www.irs.gov/individuals/international-taxpayers/closer-connection-exception-to-the-substantial-presence-test", "source_type": "official-guidance", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": true, "split_year_or_departure": "Expatriation rules (IRC 877A) apply to people who renounce US citizenship or end long-term green card residency on or after June 17, 2008. IRS guidance says a person is a covered expatriate if their average annual net income tax for the five prior years exceeds an inflation-adjusted amount ($206,000 for 2025), their net worth is $2 million or more on the expatriation date, or they do not certify on Form 8854 that they met all federal tax obligations for the five prior years. Anyone who expatriates must file Form 8854, and a $10,000 penalty may apply for not filing it. Relates to US-RES-01 and US-RES-02.", "reporting": [ { "title": "FBAR (FinCEN Form 114)", "text": "US persons with a financial interest in, or signature authority over, foreign financial accounts whose aggregate value exceeded $10,000 at any time in the calendar year file an FBAR electronically through FinCEN's BSA E-Filing System, not with the tax return. It is due April 15 with an automatic extension to October 15.", "source_url": "https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar" }, { "title": "Form 8938 (Statement of Specified Foreign Financial Assets)", "text": "Specified individuals attach Form 8938 to their income tax return when foreign financial assets exceed the thresholds for their filing status and where they live. For an unmarried taxpayer living in the US the IRS lists more than $50,000 on the last day of the year or more than $75,000 at any time; higher thresholds apply to joint filers and to taxpayers living abroad. Form 8938 does not replace the FBAR.", "source_url": "https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements" } ], "social_security": "The United States has totalization agreements with a number of countries to avoid double social security taxation; IRS guidance says these must be considered when deciding whether US Social Security and Medicare tax, or a foreign country's social security tax, applies. The current list is kept by the Social Security Administration.", "living_base": "Lawful permanent residence (a green card) lets a person live and work in the United States indefinitely; other stays rest on nonimmigrant status. Immigration status and tax status are linked but not the same: a green card makes a person a tax resident under the green card test, while physical presence alone can make a person without a green card a tax resident under the substantial presence test.", "citizenship": "Citizenship comes by birth, through a US citizen parent in some cases, or by naturalization. USCIS policy states the general requirement that a naturalization applicant has continuous residence in the United States as a lawful permanent resident for at least five years; other periods apply in specific cases. Citizens remain subject to US tax on worldwide income wherever they live.", "questions": [ "Given my citizenship or green card status, which US returns and information forms apply to me each year while I live abroad?", "How do I count my days of presence for the substantial presence test, and do any of my days fall under an exclusion or exempt-individual category?", "Do the facts of my year support a closer connection claim on Form 8840, and does anything in my immigration history block it?", "Which of my foreign accounts and assets fall within FBAR and Form 8938, and how do the two thresholds apply to me?", "How would a tax treaty between the United States and my other country of residence affect my position, and what must be disclosed to rely on it?", "If I were to give up citizenship or a long-term green card, how would the covered expatriate tests apply to my income history, net worth and filing record?", "Does a totalization agreement cover my work, and which country's social security system would apply?" ], "authorities": [ { "title": "Internal Revenue Service (IRS)", "url": "https://www.irs.gov" }, { "title": "U.S. Citizenship and Immigration Services (USCIS)", "url": "https://www.uscis.gov" }, { "title": "Financial Crimes Enforcement Network (FinCEN) BSA E-Filing", "url": "https://bsaefiling.fincen.treas.gov" } ], "sources": [ { "title": "Determining an individual's tax residency status", "url": "https://www.irs.gov/individuals/international-taxpayers/determining-an-individuals-tax-residency-status", "type": "official-guidance" }, { "title": "U.S. tax residency – Green card test", "url": "https://www.irs.gov/individuals/international-taxpayers/alien-residency-green-card-test", "type": "official-guidance" }, { "title": "Substantial presence test", "url": "https://www.irs.gov/individuals/international-taxpayers/substantial-presence-test", "type": "official-guidance" }, { "title": "Closer connection exception to the substantial presence test", "url": "https://www.irs.gov/individuals/international-taxpayers/closer-connection-exception-to-the-substantial-presence-test", "type": "official-guidance" }, { "title": "U.S. citizens and resident aliens abroad", "url": "https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-resident-aliens-abroad", "type": "official-guidance" }, { "title": "Report of Foreign Bank and Financial Accounts (FBAR)", "url": "https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar", "type": "official-guidance" }, { "title": "Comparison of Form 8938 and FBAR requirements", "url": "https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements", "type": "official-guidance" }, { "title": "Expatriation tax", "url": "https://www.irs.gov/individuals/international-taxpayers/expatriation-tax", "type": "official-guidance" }, { "title": "Totalization agreements", "url": "https://www.irs.gov/individuals/international-taxpayers/totalization-agreements", "type": "official-guidance" }, { "title": "Green Card | USCIS", "url": "https://www.uscis.gov/green-card", "type": "official-guidance" }, { "title": "USCIS Policy Manual, Volume 12, Part D, Chapter 1 - Purpose and Background", "url": "https://www.uscis.gov/policy-manual/volume-12-part-d-chapter-1", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "uy", "name": "Uruguay", "slug": "uruguay", "region": "South America", "flag": "🇺🇾", "tax_year": "Calendar year (the IRPF taxable event occurs on 31 December)", "tax_basis": "territorial", "summary": "Uruguay's personal income tax (IRPF) mainly reaches Uruguayan-source income, but resident individuals are also taxed on capital income from non-resident entities and, under the text in force from 1 January 2026, on capital gains from those assets. People who become tax residents can opt, once, for a limited-period alternative treatment of that foreign capital income; the terms changed for people becoming resident from 1 January 2026.", "residence_rules": [ { "id": "UY-RES-01", "title": "More than 183 days in the calendar year", "kind": "day-count", "text": "An individual is a tax resident if they stay in Uruguay for more than 183 days during the calendar year. Sporadic absences are counted as days in the country under conditions set by regulation, unless the person proves tax residence in another country.", "threshold_days": 183, "window": "calendar-year", "day_method": null, "source_title": "Texto Ordenado 2023 (DGI), Título 7, artículo 2 (IMPO)", "source_url": "https://www.impo.com.uy/bases/todgi2023/101-2024/2_T7", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "UY-RES-02", "title": "Main base of activities or economic or vital interests in Uruguay", "kind": "ties", "text": "An individual is also resident if the main nucleus or base of their activities, or of their economic or vital interests, is in Uruguay. The detailed criteria are set by regulation and should be checked with the DGI.", "threshold_days": null, "window": "calendar-year", "day_method": null, "source_title": "Texto Ordenado 2023 (DGI), Título 7, artículo 2, literal B", "source_url": "https://www.impo.com.uy/bases/todgi2023/101-2024/2_T7", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" }, { "id": "UY-RES-03", "title": "Presumption: spouse and dependent minor children living in Uruguay", "kind": "presumption", "text": "The law presumes, unless shown otherwise, that a person's vital interests are in Uruguay when their spouse and dependent minor children habitually live in the country.", "threshold_days": null, "window": null, "day_method": null, "source_title": "Texto Ordenado 2023 (DGI), Título 7, artículo 2", "source_url": "https://www.impo.com.uy/bases/todgi2023/101-2024/2_T7", "source_type": "primary-law", "effective": null, "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "No part-year or exit-tax rule was verified for this record. Residence is assessed per calendar year (UY-RES-01), and the IRPF taxable event occurs on 31 December of each year.", "reporting": [ { "title": "One-time option for new tax residents (Form 0306)", "text": "People who became resident from 2020 could opt once to pay non-resident income tax (IRNR) on foreign capital income for the year of the change and the ten following years, or IRPF at a reduced rate with no time limit, with the option made on Form 0306. For people becoming resident from 1 January 2026, article 24 bis allows IRNR on that income for the year of the change and ten following years, subject to a real estate investment above UI 12,500,000, an annual investment of at least UI 625,000 in qualifying funds, or meeting the 183-day test each year, and to not having been resident in the two prior years; later options include IRPF at half the rate for five years or an annual fixed amount. Check the DGI regulations for how these apply.", "source_url": "https://www.impo.com.uy/bases/todgi2023/101-2024/24_BIST7" } ], "social_security": "Uruguay appears on the CRA's list of countries with a social security agreement with Canada; check the Banco de Previsión Social and each agreement for coverage and terms.", "living_base": "The Migration Law admits foreign nationals as non-residents or residents, and divides residents into permanent and temporary; a permanent resident is someone who enters intending to settle permanently and meets the legal conditions. Migration residence and tax residence are separate: tax residence follows the IRPF tests in UY-RES-01 to UY-RES-03.", "citizenship": "The Constitution (article 75) gives foreign nationals of good conduct a right to legal citizenship after three years of habitual residence if they have a family in Uruguay and capital, property or a profession, science, art or industry, or after five years without a family in Uruguay; the political rights of legal citizenship can be exercised three years after the letter is granted. The General Assembly can also grant it for notable services.", "questions": [ "Did I spend more than 183 days in Uruguay this calendar year, and which absences count as days in the country?", "Would the DGI see my main base of activities or economic or vital interests as being in Uruguay?", "Which of my foreign income items fall within capital income from non-resident entities under the 2026 text?", "If I became resident before 2026, which option did I make or can I still make, and how do the 2026 transitional rules affect it?", "If I become resident from 2026, which of the article 24 bis conditions could I meet, and what happens after the initial period?", "Does becoming a Uruguayan tax resident change my tax residence or filing duties in my previous country?", "Which migration residence category fits my plans, and how does it relate to the residence period for legal citizenship?" ], "authorities": [ { "title": "Dirección General Impositiva (DGI)", "url": "https://www.gub.uy/direccion-general-impositiva" }, { "title": "Ministerio del Interior – Dirección Nacional de Migración", "url": "https://www.gub.uy/ministerio-interior" } ], "sources": [ { "title": "Texto Ordenado 2023 (DGI), Título 7, artículo 2 – Residentes. Personas físicas", "url": "https://www.impo.com.uy/bases/todgi2023/101-2024/2_T7", "type": "primary-law" }, { "title": "Texto Ordenado 2023 (DGI), Título 7, artículo 6 – Aspecto espacial", "url": "https://www.impo.com.uy/bases/todgi2023/101-2024/6_T7", "type": "primary-law" }, { "title": "Texto Ordenado 2023 (DGI), Título 7, artículo 7 – Período de liquidación", "url": "https://www.impo.com.uy/bases/todgi2023/101-2024/7_T7", "type": "primary-law" }, { "title": "Texto Ordenado 2023 (DGI), Título 7, artículo 24", "url": "https://www.impo.com.uy/bases/todgi2023/101-2024/24_T7", "type": "primary-law" }, { "title": "Texto Ordenado 2023 (DGI), Título 7, artículo 24 BIS – Régimen de impatriados. Rentas de capital", "url": "https://www.impo.com.uy/bases/todgi2023/101-2024/24_BIST7", "type": "primary-law" }, { "title": "Ley 20.446 – Presupuesto Nacional 2025-2029 (vigencia, artículo 3)", "url": "https://www.impo.com.uy/bases/leyes/20446-2025", "type": "primary-law" }, { "title": "TAX HOLIDAYS: Opción para nuevos residentes fiscales en Uruguay (DGI)", "url": "https://www.gub.uy/direccion-general-impositiva/comunicacion/publicaciones/tax-holidays-opcion-para-nuevos-residentes-fiscales-uruguay", "type": "official-guidance" }, { "title": "Constitución de la República, artículo 75 (IMPO)", "url": "https://www.impo.com.uy/bases/constitucion/1967-1967/75", "type": "primary-law" }, { "title": "Ley 18.250 – Migración, artículos 31 y 32 (IMPO)", "url": "https://www.impo.com.uy/bases/leyes/18250-2008/31", "type": "primary-law" }, { "title": "What is the purpose of international social security agreements? (CRA)", "url": "https://www.canada.ca/en/revenue-agency/services/tax/canada-pension-plan-cpp-employment-insurance-ei-rulings/international-social-security-agreements-canada-pension-plan/what-purpose-international-social-security-agreements.html", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" }, { "id": "za", "name": "South Africa", "slug": "south-africa", "region": "Africa", "flag": "🇿🇦", "tax_year": "Year of assessment from 1 March to the last day of February", "tax_basis": "residence", "summary": "South Africa taxes residents on worldwide income. A natural person is resident if ordinarily resident, meaning South Africa is their real home, or, if not ordinarily resident, if they meet all three parts of the physical presence test (more than 91 days this year, more than 91 days in each of the five prior years, and more than 915 days in total over those five years).", "residence_rules": [ { "id": "ZA-RES-01", "title": "Ordinarily resident test", "kind": "ties", "text": "A natural person who is ordinarily resident in South Africa is a resident. SARS notes that the courts read ordinarily resident as the country of the person's usual or principal residence, the person's real home.", "threshold_days": null, "window": null, "day_method": null, "source_title": "SARS: Taxation in South Africa 2026", "source_url": "https://www.sars.gov.za/wp-content/uploads/Ops/Guides/Legal-Pub-Guide-Gen01-Taxation-in-South-Africa.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "ZA-RES-02", "title": "Physical presence test", "kind": "day-count", "text": "A person not ordinarily resident at any time in the year of assessment is resident if physically present for periods exceeding 91 days in aggregate in that year, exceeding 91 days in each of the five preceding years, and exceeding 915 days in aggregate over those five years. A day includes part of a day, but not transit days without formally entering the country. The test is applied each year, and residence starts from the first day of the year in which all three parts are met.", "threshold_days": 915, "window": "multi-year", "day_method": "any-part", "source_title": "SARS Interpretation Note 4 (Issue 5, 3 August 2018): Resident: definition in relation to a natural person, physical presence test", "source_url": "https://www.sars.gov.za/wp-content/uploads/Legal/Notes/LAPD-IntR-IN-2012-04-Resident-definition-natural-person-physical-presence.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "ZA-RES-03", "title": "330-day rule for ceasing residence", "kind": "day-count", "text": "A person resident under the physical presence test ceases to be resident after being physically outside South Africa for a continuous period of at least 330 full days. Residence ceases from the day the person left. SARS notes this period always spans two years of assessment.", "threshold_days": 330, "window": null, "day_method": "official-guidance", "source_title": "SARS Interpretation Note 4 (Issue 5)", "source_url": "https://www.sars.gov.za/wp-content/uploads/Legal/Notes/LAPD-IntR-IN-2012-04-Resident-definition-natural-person-physical-presence.pdf", "source_type": "official-guidance", "checked": "2026-11-08" }, { "id": "ZA-RES-04", "title": "Treaty exclusion", "kind": "ties", "text": "Persons who are exclusively resident of another country for the purposes of applying a tax treaty are excluded from the definition of resident.", "threshold_days": null, "window": null, "day_method": null, "source_title": "SARS: Taxation in South Africa 2026", "source_url": "https://www.sars.gov.za/wp-content/uploads/Ops/Guides/Legal-Pub-Guide-Gen01-Taxation-in-South-Africa.pdf", "source_type": "official-guidance", "checked": "2026-11-08" } ], "citizenship_taxation": false, "split_year_or_departure": "Relates to ZA-RES-01 and ZA-RES-03. SARS says a natural person who ceases to be resident should submit a return for the period from 1 March to the day before ceasing to be resident. Ceasing to be resident is also a deemed disposal event for capital gains tax, with proceeds equal to market value.", "reporting": [ { "title": "Return on ceasing residence", "text": "A natural person who ceases to be a resident should submit a return for the period from 1 March to the day before the date of ceasing to be resident.", "source_url": "https://www.sars.gov.za/wp-content/uploads/Ops/Guides/Legal-Pub-Guide-Gen01-Taxation-in-South-Africa.pdf" } ], "social_security": null, "living_base": "Foreign nationals live in South Africa on visas and permits issued by the Department of Home Affairs. Tax residence is decided by SARS under the ordinarily resident and physical presence tests, not by the visa held.", "citizenship": "South African citizenship is administered by the Department of Home Affairs. Routes, residence periods and the position on dual citizenship are not stated here; check the Department's current guidance.", "questions": [ "Is South Africa still my real home for the ordinarily resident test, even if I live abroad?", "How many days was I physically present in each of the last six years of assessment?", "If I left South Africa, when would a continuous 330 full days outside the country be met?", "What capital gains tax follows from the deemed disposal when I cease to be resident?", "Does my foreign employment income meet the conditions of the section 10(1)(o)(ii) exemption, and what is the current cap?", "How would a tax treaty tie-breaker apply if another country also treats me as resident?" ], "authorities": [ { "title": "South African Revenue Service (SARS)", "url": "https://www.sars.gov.za/" }, { "title": "Department of Home Affairs", "url": "https://www.dha.gov.za/" } ], "sources": [ { "title": "Interpretation Note 4 (Issue 5): Resident, definition in relation to a natural person, physical presence test (SARS, 3 August 2018)", "url": "https://www.sars.gov.za/wp-content/uploads/Legal/Notes/LAPD-IntR-IN-2012-04-Resident-definition-natural-person-physical-presence.pdf", "type": "official-guidance" }, { "title": "Taxation in South Africa 2026 (SARS)", "url": "https://www.sars.gov.za/wp-content/uploads/Ops/Guides/Legal-Pub-Guide-Gen01-Taxation-in-South-Africa.pdf", "type": "official-guidance" }, { "title": "Foreign Employment Income Exemption (SARS)", "url": "https://www.sars.gov.za/individuals/tax-during-all-life-stages-and-events/foreign-employment-income-exemption/", "type": "official-guidance" } ], "checked": "2026-11-08", "review_status": "not-reviewed" } ] }