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Proof of residency

Yes.

If you look at rules like GAAR in Canada (same in most EU countries also) although not the same area as residency issue if you do no have very good lawyer ($$$$$$$) your finished.

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The General Anti-Avoidance Rule essentially states that where a transaction, or a series of transactions results in a reduction, avoidance, or deferral of taxes owing, and the transaction or the series of transactions are only being attempted for the tax benefits, the transaction or transactions themselves may be invalidated.

The Supreme Court of Canada has established a three-point test in determining whether or not to have GAAR applied.


  1. Did a tax benefit arise from the transaction or series of transactions?
  2. Is/Are the transaction(s) found to be avoidance transactions?
  3. Is the transaction abusive?
Number one is easily satisfied as nearly all transactions are done with a tax benefit in mind.

The second question asks whether the primary purpose of the transaction is to obtain a tax benefit.

The third point is the most difficult point to prove for both sides. The question it poses is whether the transaction is inconsistent with the object, purpose, or spirit of the subsection being used by the taxpayer to obtain the tax benefit.

The above test is extremely vague, and both sides can usually be argued extremely well. If the CRA claims that a taxpayer is in violation of the GAAR, it will be up to the taxpayer to prove they are not. On that same note, the CRA must prove that the GAAR applies.

Guarding against the GAAR is extremely complex. If you are planning a transaction, or a series of transactions that might run afoul of the GAAR, you should seek immediate legal assistance.



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I just learned that tax in Denmark is 50% and goes up to 70% for people who relocated and have no treaties (will be double taxed) that's insane - isn't it close to "forced labor" already, where people are slaves to their state/emperor for real?
 
I just learned that tax in Denmark is 50% and goes up to 70% for people who relocated and have no treaties (will be double taxed) that's insane - isn't it close to "forced labor" already, where people are slaves to their state/emperor for real?

Are you serious? :oops:
 
Do you think it's fine to show them expenses in a 3rd country if i live part of my time there (so i can proof i was outside my own country, but in this case not in my new residency country) or not?

Also it can work if after getting the tax residence in aow tax jurisdiction you move in a 3rd country with nomad visa (so you have to proof to be there and not in the other low tax jurisdiction country)

As explained before, this all depends on the rules of your home country. Some countries are OK with you being not in your home country anymore. Others require proof you live somewhere else permanently, i.e. it's not good enough for them if you're a nomad.

I just learned that tax in Denmark is 50% and goes up to 70% for people who relocated and have no treaties (will be double taxed) that's insane - isn't it close to "forced labor" already, where people are slaves to their state/emperor for real?

You mean income paid by a Danish employer? Because as far as I know, Denmark is otherwise fine with people just leaving. I've met some Danish nomads during my travels and they told me they don't have to pay taxes in Denmark.
 
I've met some Danish nomads during my travels and they told me they don't have to pay taxes in Denmark.
If you leave the country you won't need to pay taxes in Denmark, but that requires that you give up all ties to the country.
 
As explained before, this all depends on the rules of your home country. Some countries are OK with you being not in your home country anymore. Others require proof you live somewhere else permanently, i.e. it's not good enough for them if you're a nomad.



You mean income paid by a Danish employer? Because as far as I know, Denmark is otherwise fine with people just leaving. I've met some Danish nomads during my travels and they told me they don't have to pay taxes in Denmark.
I recently interviewed with a company in Denmark and they told me that about the income taxes. It's for people who relocate to Denmark and live there I mean :)
 
Ah, yes, absolutely. But why would you be double taxed if you move to Denmark?
I won't be, but the people who interviewed me told me that some who relocate, get into a situation with double tax in their country and end up with up to 70% total tax. I wonder how these countries with high taxes even attract people to move there. Probably the ones who want to relocate on these terms are people from countries where things are so bad that they're trying to at least survive :oops:
 
Do you guys knows where would you pay taxes if you move from a country A (Italy, France, etc) to a country B (Romania, Bulgaria, etc) you get your residency and you open your company there and then after that you move to another country with the digital nomad visa (which say you pay zero taxes in that country because you are supposed to pay them in your country of residence)?
 
@ilpablo That would depend on the laws of country A and country B. Obviously there's a high chance that country A and C wouldn't care because they think you're paying taxes in country B. And country B may not care because you actually live in country C. But if you ever move back to country A or for some reason, there's an audit in country A (or potentially in country B), then they could demand you pay taxes there, since you didn't pay taxes in country C.
 
Probably the ones who want to relocate on these terms are people from countries where things are so bad that they're trying to at least survive

Yup like Afghan programmers smi(&%
 
@ilpablo That would depend on the laws of country A and country B. Obviously there's a high chance that country A and C wouldn't care because they think you're paying taxes in country B. And country B may not care because you actually live in country C. But if you ever move back to country A or for some reason, there's an audit in country A (or potentially in country B), then they could demand you pay taxes there, since you didn't pay taxes in country C.
But if i paid taxes in country B, while i was living in country C with the digital nomad visa, how can country A claim again some taxes?
 
But if i paid taxes in country B, while i was living in country C with the digital nomad visa, how can country A claim again some taxes?

It would depend on the laws of country A, obviously. It's not enough to pay taxes, you also have to pay them to the right country.

Fictitious example. Say the tax laws of country A say: "You cease to be tax resident in country A if and only if you take up permanent residency in and become tax resident of a country that we have signed a tax treaty with. Otherwise you will remain tax resident in country A."
Country A has signed a tax treaty with country B. But country B only considers you tax resident if you spend at least 60 days per year in the country.
Now you move to country B on paper, but you really live in country C.
Country C says "if you are in our country on a digital nomad visa, you cannot be considered tax resident" - and country C also hasn't signed a tax treaty with country A. So country C is out.
But country B is also out since you're not spending the required 60 days there, thereby no longer fulfilling the "you are tax resident of a country we have signed a tax treaty with" condition.
So based on that you would remain tax resident in country A and have to pay taxes there.
But that's just something I made up now to illustrate a hypothetical problem. In practice, I cannot imagine this would be an issue. But you should work with tax lawyers from countries A and B to be sure.
 

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