Where do I pay tax if I don't live 183 days in any country in a calendar year?

[Dorinka1988]

Where do I pay tax if I don't live 183 days in any country in a calendar year?

SO, my situation is as follows.

From 2012-2022 I lived in Thailand, but have no banks there and property, I have no kids, not married.

In 2023 I moved to Spain and will be living here for 5 months until May, then move to Portugal for 5 months and transfer to another country after that.

I am originally from Czech Republic but did not live there since 2012 and have no center of business there.

I am working since 2023 remotely for company based in Seychelles.

If I will not live in any country for more than 183 days, so where do I pay taxes if ever I need to pay tax anywhere if my tax is only earned out of countries I live and they have all 183 days rule.

I have no attachment to the country I was born in for past 11 years, no bank, house or anything like that.

What happens in that case in terms of taxes for 2023?

My contract says im 100% responsible for my own taxes and receiving full salary without any deductions.

Will I have to pay any taxes or will anyone ask me for that, since I will not live in any of the countries for 6 months?

I hope to get some clarification on this.

Thanks!

 

[JohnnyDoe]

Absent any proof of residence in another country, you are liable to taxation in Czechia. Potentially, also in other countries.
It’s better if you hire a good advisor to fix your situation.

 

[Dorinka1988]

Absent any proof of residence in another country, you are liable to taxation in Czechia. Potentially, also in other countries.
It’s better if you hire a good advisor to fix your situation.

Wouldn't proof of residence will be that I lived in Thailand and work there before and paid taxes there, and what if I go back there before the end of this year, wouldn't that will be considered my center of business? Considering that I will stop working in 2023 in Europe and go back to Thailand by end of year. So in past 10 years in Czech I have no connection and only place I worked and paid taxes for work was Thailand.

 

[Mike Forman]

Wouldn't proof of residence will be that I lived in Thailand and work there before and paid taxes there, and what if I go back there before the end of this year, wouldn't that will be considered my center of business? Considering that I will stop working in 2023 in Europe and go back to Thailand by end of year. So in past 10 years in Czech I have no connection and only place I worked and paid taxes for work was Thailand.

Did you pay taxes there? You didn't have a bank account you stated, so I would be doubtful that you had legit income there and paid taxes.

What residence address is registered in Czech, Thailand?

Where did you get your income from and how did you pay expenses? In which jurisdiction was this account located?

If you are just a few months in Europe and be back in Asia end of the year you should have little issues, but just as with any tax authority going after you, sometimes just any event trigger can put you in a difficult position, such as crs exchange to Czech of a local /foreign bank account. And then you will be required to provide all proof you lived abroad, paid taxes abroad etc. Already not having a bank account in the country you live (Thailand) already means your center of your finances is not in Thailand, hence Czech or any other country believing you should have paid tax there could tax you.

You need to consult some tax lawyers if you want to minimize the risk

 

[Dorinka1988]

Did you pay taxes there? You didn't have a bank account you stated, so I would be doubtful that you had legit income there and paid taxes.

What residence address is registered in Czech, Thailand?

Where did you get your income from and how did you pay expenses? In which jurisdiction was this account located?

If you are just a few months in Europe and be back in Asia end of the year you should have little issues, but just as with any tax authority going after you, sometimes just any event trigger can put you in a difficult position, such as crs exchange to Czech of a local /foreign bank account. And then you will be required to provide all proof you lived abroad, paid taxes abroad etc. Already not having a bank account in the country you live (Thailand) already means your center of your finances is not in Thailand, hence Czech or any other country believing you should have paid tax there could tax you.

You need to consult some tax lawyers if you want to minimize the

Hey, yes I was legally hired, paid taxes, got working visa and got bank payroll account but bank account will be closed this year due to inactivity. Might be good idea to keep that bank account or send some funds there?

I have no bank in Czech and no funds were transferred there by me for all past years.

 

[JohnnyDoe]

Hey, yes I was legally hired, paid taxes, got working visa and got bank payroll account but bank account will be closed this year due to inactivity. Might be good idea to keep that bank account or send some funds there?

I have no bank in Czech and no funds were transferred there by me for all past years.

Then you are covered for the period you stayed in Thailand. You shouldn’t have issues with Czechia, provided that you cut all your ties with this country, but you should now find a place to call residence, where you should get a formal residence permit.

 

[Larin]

Absent any proof of residence in another country, you are liable to taxation in Czechia. Potentially, also in other countries.
It’s better if you hire a good advisor to fix your situation.

This is blatantly incorrect. As per PwC, he would not be considered a tax resident in the Czech Republic: Czech Republic - Individual - Residence

As so where you would be considered a tax resident, based on what you've provided, nowhere. However, since you will be working in Spain and Portugal, technically speaking this will be locally sourced income (since you will be physically in these countries while performing the work). Therefore, technically speaking you will be liable to pay tax in each jurisdiction that you work. Enforceability and situation on the ground is a different matter entirely.

See Spanish residence rules summary here: Spain - Individual - Residence

 

[JohnnyDoe]

As so where you would be considered a tax resident, based on what you've provided, nowhere.

keep dreaming of the legendary PT life. Nobody can be tax resident nowhere.
Hire a tax advisor/accountant.

 

[Dorinka1988]

This is blatantly incorrect. As per PwC, he would not be considered a tax resident in the Czech Republic: Czech Republic - Individual - Residence

As so where you would be considered a tax resident, based on what you've provided, nowhere. However, since you will be working in Spain and Portugal, technically speaking this will be locally sourced income (since you will be physically in these countries while performing the work). Therefore, technically speaking you will be liable to pay tax in each jurisdiction that you work. Enforceability and situation on the ground is a different matter entirely.

See Spanish residence rules summary here: Spain - Individual - Residence

Hello, but the income is not local as the income is online and also it is fully paid in crypto, I have no bank in spain only some emi, also i will be living in spain only for a little over 4 months in this calendar year, if I will start sending money to my bank in thailand and later go bck to that country after completing the job already later this year, wouldnt that save me from taxas in spain and portugal?

 

[Dorinka1988]

I won't live in any of these countries for 183 days, so that means this rule would not be applicable for me if I understand this correctly, in that case I guess I need to pay taxes where my center of business is, and right now, I have no one, so maybe I can go around that and send money to thai bank, also my gf is living there so i guess that adds to center of business, no clue what to do

so if I will work in Spain 5 months and 5 months in portugal and go back to Thailand end of year, I guess I wont have to pay anyting in spain and portugal right? Will anyone ask me anything when I will be living Spain after 5 months staying here? Im actully 8 months here but came in october 2022 and will leave in may 2023

 

[Sols]

I won't live in any of these countries for 183 days, so that means this rule would not be applicable for me if I understand this correctly, in that case I guess I need to pay taxes where my center of business is, and right now, I have no one, so maybe I can go around that and send money to thai bank, also my gf is living there so i guess that adds to center of business, no clue what to do

What do you mean by "get around"? That sounds like you are evading some tax rules. You know, sort of like tax evasion.

I'm not saying that's the case but you have to think like a tax authority and look at what you're doing from their perspective.

so if I will work in Spain 5 months and 5 months in portugal and go back to Thailand end of year, I guess I wont have to pay anyting in spain and portugal right? Will anyone ask me anything when I will be living Spain after 5 months staying here? Im actully 8 months here but came in october 2022 and will leave in may 2023

Congratulations, you are tax resident in Spain, either wholly or partly. Now open up your wallet and let the hacienda take what it wants. If they take too much, you will have to take them to court.

You are also tax resident in Portugal, so be prepared to do the same there.

In reality, unless you're worth a few million, you'll not end up on anyone's radar in the near future. For now. Perhaps. It would be unusual but not unheard of.

As @JohnnyDoe said. Forget PT. Find a good place to be tax resident in and travel the world as a normal tourist only.

 

[uplana]

question:
If I move around instantly, or at least every 5 - 6 months and have cut all my ties to my current country where I lived the last 25 years. Why would I be tax liable anywhere, and if liable where?

 

[JohnnyDoe]

question:
If I move around instantly, or at least every 5 - 6 months and have cut all my ties to my current country where I lived the last 25 years. Why would I be tax liable anywhere, and if liable where?

Absent anything else, in the country of which you are a citizen.

 

[backpacker]

Absent anything else, in the country of which you are a citizen.

That's hardly correct. As long as you do not know the countries involved, your reply is simply speculation.

question:
If I move around instantly, or at least every 5 - 6 months and have cut all my ties to my current country where I lived the last 25 years. Why would I be tax liable anywhere, and if liable where?

Post #7 @Larin is correct. You can deduce from its conclusion.

 

[JohnnyDoe]

That's hardly correct. As long as you do not know the countries involved, your reply is simply speculation.

another PT dreamer.
If you don't have a residence or domicile, you are taxed based on nationality. Even stateless persons that don't have a residence or domicile are liable to taxation, in their country of birth.
Then you have to check the rules of that specific country to understand whether the tax liability translates into any actual tax.
It is not such an uncommon situation, for example for those who live on a boat at sea.

 

[Mike Forman]

I won't live in any of these countries for 183 days, so that means this rule would not be applicable for me if I understand this correctly, in that case I guess I need to pay taxes where my center of business is, and right now, I have no one, so maybe I can go around that and send money to thai bank, also my gf is living there so i guess that adds to center of business, no clue what to do

so if I will work in Spain 5 months and 5 months in portugal and go back to Thailand end of year, I guess I wont have to pay anyting in spain and portugal right? Will anyone ask me anything when I will be living Spain after 5 months staying here? Im actully 8 months here but came in october 2022 and will leave in may 2023

If you are only talking about one time 5 months in each country there would be little to no risk you ever encounter tax authorities. You are not in Czech so you would stay under the radar. Keep proof of entering and leaving the county (boarding passes etc)

You have substantial proof of living and income in Thailand from what you have confirmed, so your past is covered. Make sure you keep all your bank statements, tax certificates, proof of spending, living etc.

My advice is not any legal advice, you have to consult a tax consultant who is experienced with each jurisdiction you plan to stay for a significant time, but if this is just a one time occasion of 5 months I wouldn't worry or bother much.

If you would do this every year and don't pay any income taxes anywhere you might get in trouble one day, so it's always better to be a resident somewhere (low tax jurisdiction) and pay some taxes there.

 

[backpacker]

another PT dreamer.
If you don't have a residence or domicile, you are taxed based on nationality. Even stateless persons that don't have a residence or domicile are liable to taxation, in their country of birth.
Then you have to check the rules of that specific country to understand whether the tax liability translates into any actual tax.
It is not such an uncommon situation, for example for those who live on a boat at sea.

Well, I am not a PT dreamer since I am not a PT and do not have the intention or need to become one.
There is no doubt that it is better to have residency somewhere. And most people have residency somewhere, even if they think they do not.
However, what you state is a simplification of a complicated matter.

Show me the compendium of the World Tax Organisation (if you are able to find that organisation) where these general rules are stated ->

If you don't have a residence or domicile, you are taxed based on nationality

Even stateless persons that don't have a residence or domicile are liable to taxation, in their country of birth.

We can continue discussion once you have produced them. Otherwise, let's leave it here - not worth wasting anymore time on this.

 

[bubbledouble]

What is a "PT" ?

But how about the tax rule, if you are not living in the same country more then 183 days you don't need to pay tax there. That would mean, I would need to be tax resident for instant in Switzerland or some Banana republic to get the lowest possible tax rate and pay the tax rate there?

 

[backpacker]

What is a "PT" ?

But how about the tax rule, if you are not living in the same country more then 183 days you don't need to pay tax there. That would mean, I would need to be tax resident for instant in Switzerland or some Banana republic to get the lowest possible tax rate and pay the tax rate there?

PT = Perpetual Traveller

Forget about the 183-day-rule. It is an imaginary rule which is used by some countries to determine tax residency but it is rarely the only rule. So, you have to dig into individual tax codes of each country + tye tax code of your country of citizenship to determine if/where you are a tax resident.

 

[JohnnyDoe]

Show me the compendium of the World Tax Organisation (if you are able to find that organisation) where these general rules are stated ->


We can continue discussion once you have produced them. Otherwise, let's leave it here - not worth wasting anymore time on this.

https://read.oecd-ilibrary.org/taxa...e-and-on-capital-2010_9789264175181-en#page36M-13 art.4 par. 2.c,d
And plenty of other sources.
This provision is dictated by common sense, which is the first (necessary but not sufficient) tool you need for understanding taxation.