Tax Residency Rules by Country: Complete Reference
Understanding where you are a tax resident is the first step in international tax planning. This guide covers the residency rules for 20+ countries.
| Country | Days Threshold | Other Criteria | Tax System |
|---|---|---|---|
| United States | 183 days (substantial presence test with weighted calculation) | Citizenship-based taxation; Green Card test | Worldwide |
| United Kingdom | Statutory Residence Test (16-183 days depending on ties) | Automatic overseas test, sufficient ties test, split-year treatment | Worldwide (remittance basis available) |
| Germany | 183 days | Habitual abode (gewohnlicher Aufenthalt), domicile (Wohnsitz) | Worldwide |
| France | 183 days | Foyer (family home), professional activity center, center of economic interests | Worldwide |
| Netherlands | No fixed threshold | Durable ties: home, family, social/economic connections | Worldwide |
| Singapore | 183 days | Physical presence; no tax on foreign-sourced income not remitted | Territorial (modified) |
| Australia | No fixed threshold | Domicile test, 183-day test, superannuation test, family ties | Worldwide |
| Canada | 183 days (sojourner rule) | Significant residential ties: home, spouse/dependents, personal property | Worldwide |
| Ireland | 183 days (or 280 over 2 years) | Domicile, ordinary residence (3 consecutive years) | Worldwide (remittance basis for non-domiciled) |
| Switzerland | 30+ days (with gainful activity) or 90+ days (without) | Registered domicile, intent to remain | Worldwide |
| Spain | 183 days | Center of economic interests, family residence in Spain | Worldwide |
| Portugal | 183 days | Having a habitual residence (habitual abode test) | Worldwide |
| Italy | 183 days (reformed 2024: physical presence focus) | Civil registry, domicile, habitual abode | Worldwide |
| Belgium | No fixed threshold | Domicile (registered address), seat of wealth | Worldwide |
| Austria | 183 days | Domicile (Wohnsitz), habitual abode | Worldwide |
| India | 182 days (or 60 days + 365 in prior 4 years) | Ordinary residence requires 2 of 10 preceding years as resident | Worldwide (residents), Territorial (non-residents) |
| UAE | 183 days (new rule from 2023) | Previously no formal residency test; now has administrative criteria | No income tax |
| Brazil | 183 days in any 12-month period | Permanent visa holders are automatically residents | Worldwide |
| Israel | 183 days (or 30+ days with 425+ over 3 years) | Center of life test | Worldwide |
| New Zealand | 183 days in any 12-month period | Permanent place of abode | Worldwide |
Understanding Tie-Breaker Rules
When you qualify as a tax resident of two countries simultaneously (dual residence), the double taxation treaty between those countries determines which country has primary taxing rights. The OECD Model Tax Convention provides a standard hierarchy:
- Permanent home: The country where you have a permanent home available to you. If you have a home in both countries, proceed to the next test.
- Center of vital interests: The country where your personal and economic relations are closer. This considers family, social connections, occupations, political activities, and place of business.
- Habitual abode: The country where you spend more time.
- Nationality: Your citizenship.
- Mutual agreement: If none of the above resolves it, the two countries must negotiate.
How to Change Your Tax Residency
Changing tax residency requires concrete steps in both the departure and arrival country:
Departure Steps
- Notify the tax authority of your departure (e.g., Abmeldung in Germany, Form P85 in the UK)
- Close or redirect your local bank accounts
- Terminate your lease or sell your property
- Cancel local subscriptions and memberships
- Update your address with all institutions
- File a final tax return covering the period up to your departure date
Arrival Steps
- Register with the local authorities (e.g., Anmeldung in Germany, register at the commune in Belgium)
- Obtain a local tax identification number
- Open a local bank account
- Sign a rental agreement or property purchase
- Register for social security and health insurance
- Apply for any special tax regimes (NHR in Portugal, Beckham Law in Spain, etc.)
Worldwide vs. Territorial Taxation
Countries fall into two broad categories:
- Worldwide taxation: Tax residents are taxed on their global income, regardless of where it is earned. Most developed countries use this system (US, UK, Germany, France, Australia, etc.).
- Territorial taxation: Only income earned within the country is taxed. Foreign-sourced income is exempt. Examples include Singapore (modified territorial), Hong Kong, Panama, Paraguay, and Costa Rica.
Even countries with worldwide taxation often provide mechanisms to avoid double taxation: foreign tax credits, tax treaties, and exemptions for specific types of foreign income.
For a visual comparison of take-home pay across countries, visit our World Tax Map.
Disclaimer: This guide is for educational purposes only. Tax residency rules are complex and subject to change. Always consult a qualified tax professional in both your departure and arrival countries.
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