Being a tax resident in 2 EU countries at once?

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gnud

Entrepreneur
Is it possible to be a tax resident in 2 EU countries at once?

If I'm a tax resident in country A, rent there an apartment, and then go to country B, rent there another apartment, register myself as a resident there, but won't unregister from country A, will I end up with 2 tax ids without the two administrations knowing about each other?
If yes, and they don't exchange actual tax residency information based on some unique international identifier it seems like a significant flaw.
And what can be even an unique international identifier? A person can have multiple citizenships and multiple passports, multiple national ID cards etc. Only DNA is able to uniquely identify a person ...

This hack, if possible, is likely illegal, but still interesting.
 
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gnud

Entrepreneur
I don't see the benefit in doing this.. What is the point of doing this?

Wanting to live in a high tax country, but having assets in a low tax country - eliminating a link between your personal identity in a high tax country from a personal identity in a low tax country.

If you possess a business or bank accounts in a low tax country, tax authorities in the high tax country wouldn't ever be able to discover them, as there's no connection. The low tax country wouldn't even exchange the information through the CRS with the high tax country as you'd have a local residency there in they eyes. The high tax country wouldn't even demand the information as it'd have no knowledge of the assets abroad, and in their eyes you'd be their local resident too.

I believe this is the reason why some people are obsessed with collecting citizenships.
 

fshore

Entrepreneur
Yes it's absolutely possible to be tax resident in 2 or more countries at once. But it's normally not desirable.
The tax authorities will not automatically exchange any information in any case. It's the banks that will exchange the information. So you would have to not tell the banks about your other residents, and you could as well do that without being tax resident in the low country.
 

gnud

Entrepreneur
The only problem I can think of, beside it being probably illegal, is you'll never be able to bring any significant sums to the high tax country in your name to purchase e.g. real estate, as they'd demand you to prove the origin of your wealth.
 

gnud

Entrepreneur
Yes it's absolutely possible to be tax resident in 2 or more countries at once. But it's normally not desirable.
The tax authorities will not automatically exchange any information in any case. It's the banks that will exchange the information. So you would have to not tell the banks about your other residents, and you could as well do that without being tax resident in the low country.

Excellent, so the way around the CRS is to simply register yourself as a tax resident in multiple countries, ideally each time with a different passport. Illegal, but undetectable.
 

fshore

Entrepreneur
Excellent, so the way around the CRS is to simply register yourself as a tax resident in multiple countries, ideally each time with a different passport. Illegal, but undetectable.
I think you misunderstand. You don't register yourself as a tax resident. You become tax resident if you fulfill the criteria for being a tax resident. Its certainly not illegal to be tax resident in multiple countries.
To not report offshore assets to the counties where you are tax resident is "illegal".
 

gnud

Entrepreneur
I think you misunderstand. You don't register yourself as a tax resident. You become tax resident if you fulfill the criteria for being a tax resident. Its certainly not illegal to be tax resident in multiple countries.
To not report offshore assets to the counties where you are tax resident is "illegal".

Of course, I understand, you need to fulfill criteria, but who checks them normally? With open borders they'd have to do weekly checks of whole populations to verify if they really reside where they claim they do. Do you think all the millionaires and billionaires really live in the tiny apartments in Monaco?

Rent one apartment in a high tax country, another in a low tax country, set up business in the low tax country, register yourself for health insurance etc, open there accounts with the address in the low tax country, go back home to your high tax country and lead a regular life while running your business in the low tax country. If you don't report it (as you're obliged to), they will never know.

I'm pretty sure though the day will come when they'll start sharing tax residency info with passport IDs, full names, dates and places of birth etc, at least in the EU. And then you'll be fucked with such scheme, especially if they'll apply it retroactively on historical records. However so far nothing is planned for at least the next 2 years.
 
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gyorgy

New member
You can be tax resident in 2 eu countries. In that case there is DTA between them defining how they treat you. In my case i could pick where i want to be tax resident, i would ask for tax resident certificate and show it to second country so they dont bother me.
 

gnud

Entrepreneur
You can be tax resident in 2 eu countries. In that case there is DTA between them defining how they treat you. In my case i could pick where i want to be tax resident, i would ask for tax resident certificate and show it to second country so they dont bother me.

Do they automatically exchange tax residency information based on e.g. passport? Can you be a tax resident of both, have 2 tax ids, without them knowing about each other?
 

Rzeznik

Active Member
Do they automatically exchange tax residency information based on e.g. passport?
No they don't do that. Procedure of clarification is described in treaties if there is conflict.
Taxpayer have to start it they have up to 3 years to clear that.

Can you be a tax resident of both, have 2 tax ids, without them knowing about each other?
In theory yes but institutions are those who report. Institutions can report you in multiple places if you have different phones / different residential addresses / transact a lot with X jurisdictions.

Your plan can have flaw if you **** up and lets say in country A open bank account using TIN form country B. Technology is improving and probably once


The high tax country wouldn't even demand the information as it'd have no knowledge of the assets abroad, and in their eyes you'd be their local resident too.
In theory yes but in practice there are regular leaks, because some "morons" has setup CRS :) and not only, if tax data will leak form country A and country B will look for its taxpayer then they got you. There are even bounties for those tax data so you can have problems. Tax departments are analysing such reports so be aware of that.
Much cheaper is probably holding USDC today till crypto CRS will come.

I believe this is the reason why some people are obsessed with collecting citizenships.
Those people probably overplayed, because if you look at EU blacklist now only 3 countries left as not cooperative. Those passports can save your *** when home country won't renewal your passport until for some reason or you have expired.
In EU they collect country/place of birth so most exotic passport won't help you if they want find you. They are not idiots. You can open bank account outside EU but SWIFT wires will cost you a lot. Most clean ways of tax evasion is now closed you have to move away.

And then you'll be fucked with such scheme, especially if they'll apply it retroactively on historical records.

Under CRS if you are big fish and institution will detect you second tax residency they will report you in both places. They will share information on you 5 years back.

page 36 c2 if they detect anomaly they will send to both places. page 35 5b.
 
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pixbix

New member
The only problem I can think of, beside it being probably illegal, is you'll never be able to bring any significant sums to the high tax country in your name to purchase e.g. real estate, as they'd demand you to prove the origin of your wealth.

That's false. banks are the ones doing KYC/AML. Also if you were taxed in another country is also fine , even for the government ,as there are a lot of "double taxation treaties " between almost all countries

Those people probably overplayed, because if you look at EU blacklist now only 3 countries left as not cooperative. Those passports can save your *** when home country won't renewal your passport until for some reason or you have expired.

which are those 3 countries names?
 
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Rzeznik

Active Member
which are those 3 countries names?

The EU list of non-cooperative jurisdictions for tax purposes​

The list adopted by the Council on 24 February 2022 is composed of:

  • American Samoa
  • Fiji
  • Guam
  • Palau
  • Panama
  • Samoa
  • Trinidad and Tobago
  • US Virgin Islands
  • Vanuatu

Now is bit more but here is official list is changing.
 
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