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Which countries require a personal tax residency certificate?

JustAnotherNomad

Entrepreneur
Countries like the UAE or Panama consider you tax resident when you are a permanent resident, even if you hardly spend any time in the country.
However, to be issued a tax residency certificate, you must spend 183 days per year there (more or less). I’m assuming they are stricter with the certificates because they don’t want to be accused by other countries of supporting tax evasion.

But who would actually need such a certificate?
As far as I have understood, some countries require a tax certificate to “let go” of you. They want to see that you’ve properly established tax residency somewhere else. Fair enough.
Let’s call them category A countries.

But many countries don’t have such rules. You just leave, cut all your ties with that country and they don’t care where you live, not even if you’re a citizen. Sometimes they still tax you for some years, just because, but that’s it.
Let’s call them category B countries.

On the other hand, a tax residency certificate doesn’t necessarily offer protection against other countries ALSO claiming you as a tax resident. For example, if you spend 61 days per year in Cyprus (60 days is the minimum to be considered tax resident), but you also spend 124 days in France, where your wife and kids live, then you can bet that France will demand that you pay your taxes there, and you can bet that the tie-breaker rules in the tax treaty will give France the right to tax your worldwide income, except your Cyprus-sourced income maybe, or with credit for taxes already paid elsewhere.

So who actually needs the certificate? Only former tax residents of category A countries? Which countries would that be?
 

Davis123

Active Member
Countries like the UAE or Panama consider you tax resident when you are a permanent resident, even if you hardly spend any time in the country.
However, to be issued a tax residency certificate, you must spend 183 days per year there (more or less). I’m assuming they are stricter with the certificates because they don’t want to be accused by other countries of supporting tax evasion.

But who would actually need such a certificate?
As far as I have understood, some countries require a tax certificate to “let go” of you. They want to see that you’ve properly established tax residency somewhere else. Fair enough.
Let’s call them category A countries.

But many countries don’t have such rules. You just leave, cut all your ties with that country and they don’t care where you live, not even if you’re a citizen. Sometimes they still tax you for some years, just because, but that’s it.
Let’s call them category B countries.

On the other hand, a tax residency certificate doesn’t necessarily offer protection against other countries ALSO claiming you as a tax resident. For example, if you spend 61 days per year in Cyprus (60 days is the minimum to be considered tax resident), but you also spend 124 days in France, where your wife and kids live, then you can bet that France will demand that you pay your taxes there, and you can bet that the tie-breaker rules in the tax treaty will give France the right to tax your worldwide income, except your Cyprus-sourced income maybe, or with credit for taxes already paid elsewhere.

So who actually needs the certificate? Only former tax residents of category A countries? Which countries would that be?
Mostly EU countries who are now trying to find every penny that is why they are doing these type of blatant blackmailing. Well even USA requires you to file whether you live in another country for 365 days a year. USA is best bet for foreigners to invest as taxes are zero for them mostly. But US changes its law often. So be mindful of them.
 

JustAnotherNomad

Entrepreneur
The US has a well-defined substantial presence test for foreigners. And I believe US citizens only pay US tax on income exceeding $100k if they are out of the country for more than X days.

And “most EU countries” certainly don’t require a tax residency certificate. They may demand proof that you’ve been out of the country, but that doesn’t have to be presented in the form of a tax residency certificate. Thus my question.
 

Davis123

Active Member
The US has a well-defined substantial presence test for foreigners. And I believe US citizens only pay US tax on income exceeding $100k if they are out of the country for more than X days.

And “most EU countries” certainly don’t require a tax residency certificate. They may demand proof that you’ve been out of the country, but that doesn’t have to be presented in the form of a tax residency certificate. Thus my question.
Your RFID passport is your biggest proof. ‍♂. If you have dual one to get inside Switzerland I guess you can always come through EU border but then again your EU card might flag you. That is why we are seeing all this blackmailing going on.
 

JustAnotherNomad

Entrepreneur
You’re speaking in tongues. Can you please be a bit more explicit? Who is blackmailing who and what does that have to do with my question about tax residency certificates?
 

Konstanz

New member
The US has a well-defined substantial presence test for foreigners. And I believe US citizens only pay US tax on income exceeding $100k if they are out of the country for more than X days.

And “most EU countries” certainly don’t require a tax residency certificate. They may demand proof that you’ve been out of the country, but that doesn’t have to be presented in the form of a tax residency certificate. Thus my question.
In my EU home country, there are no official laws that require you to hold another country tax residency certificate. However, they always request to show it. It's proof that other country claims you to be their tax resident. Without it, it's much harder to prove that you are not a resident in home country. How can you claim you are not a resident in the home country if you don't hold any other country tax residency certificate? This is the question most EU countries would ask..
 

Davis123

Active Member
You’re speaking in tongues. Can you please be a bit more explicit? Who is blackmailing who and what does that have to do with my question about tax residency certificates?
It's EU/OECD who is blackmailing countries like UAE, Panama etc to make their laws more tax unfriendly and system checks as they are experiencing a heavy drain of wealth flowing to UAE, Singapore and Panama. They are suspending transfers all the time. UAE has not being blackmailed one time but multiple times already. Amazing they haven't done anything about Singapore as of yet. Singapore is superb for rich and wealthy clients.
 

Konstanz

New member
It's EU/OECD who is blackmailing countries like UAE, Panama etc to make their laws more tax unfriendly and system checks as they are experiencing a heavy drain of wealth flowing to UAE, Singapore and Panama. They are suspending transfers all the time. UAE has not being blackmailed one time but multiple times already. Amazing they haven't done anything about Singapore as of yet. Singapore is superb for rich and wealthy clients.
What do you exactly mean blackmailing? UAE is still 0% tax country.
What do you mean RFID passport, do you mean they scan these passports in/exit wirelessly on borders in Schengen?
 

KJK

Entrepreneur
(...)
Let’s call them category A countries.
(...)
Sometimes they still tax you for some years, just because, but that’s it.
Let’s call them category B countries.

So who actually needs the certificate? Only former tax residents of category A countries? Which countries would that be?
This categorization makes sense. However, there is no clear line and no clear list of which country belongs to which of these categories.
It may depend on many factors - who you are, who is investigating your case (if anyone), whether you have enemies, whether you are public figure etc etc.

In the end you may have person 1 and person 2 from the same country but for one of them the "A" category may apply and for the other one the "B" category may apply, simply because their case was handled by another tax official.

Also don't forget there is a third category, category "C" or what you could call "fuck you either way countries", right now these are United States, Hungary and Eritrea.
 

Davis123

Active Member
What do you exactly mean blackmailing? UAE is still 0% tax country.
What do you mean RFID passport, do you mean they scan these passports in/exit wirelessly on borders in Schengen?
Almost all passports these days have this chip embedded into them since past 8 to 10 years. Your entire bio data is on these passports. You don't have to go through some guy in Immigration to stamp your passport anymore. You just place your passport in a scanner in a booth in UAE or Singapore or many US international airports and world airports and they let you walk to customs. In UAE you can also put your Emirates ID inside the card slot for a few min while system scans you and it will let you go provided the systems are working fine.
 

Konstanz

New member
Almost all passports these days have this chip embedded into them since past 8 to 10 years. Your entire bio data is on these passports. You don't have to go through some guy in Immigration to stamp your passport anymore. You just place your passport in a scanner in a booth in UAE or Singapore or many US international airports and world airports and they let you walk to customs. In UAE you can also put your Emirates ID inside the card slot for a few min while system scans you and it will let you go provided the systems are working fine.
My question is can they scan it remotely to track particular person movement in the country. In Schengen, there are no checks on borders.
 

Davis123

Active Member
What do you exactly mean blackmailing? UAE is still 0% tax country.
What do you mean RFID passport, do you mean they scan these passports in/exit wirelessly on borders in Schengen?
Blackmailing means suspending transactions between EU and UAE or between EU and other country for that matter.
 

Davis123

Active Member
My question is can they scan it remotely to track particular person movement in the country. In Schengen, there are no checks on borders.
Well you have more idea over there. I haven't travelled to Shengan area for sometime now. I am not from EU but I know many people from EU who live in UAE full time as expats. Life here in UAE is better for most expats. It's the best place in the world to live tax free but move your money to Singapore as better idea.
 

KJK

Entrepreneur
My question is can they scan it remotely to track particular person movement in the country. In Schengen, there are no checks on borders.
Yes, unfortunately they can. Officially the data is retained for 6 months, unofficially you honestly have no fucking idea whether/when it is deleted.
 

Konstanz

New member
Yes, unfortunately they can. Officially the data is retained for 6 months, unofficially you honestly have no fucking idea whether/when it is deleted.
This is about airlines. How about land travel, trains , bus, cars etc? Do they scan it once in the country.
 

JustAnotherNomad

Entrepreneur
Almost all passports these days have this chip embedded into them since past 8 to 10 years. Your entire bio data is on these passports. You don't have to go through some guy in Immigration to stamp your passport anymore.
So?! Do you think it would be different if the border police officer manually swiped your passport?! Your data will be stored when you cross a border. That’s the way things are and it has absolutely nothing to do with blackmailing.
The EU pushing for substance requirements in countries like the UAE I actually regard as positive because it gives the UAE more legitimacy.
 

JustAnotherNomad

Entrepreneur
In my EU home country, there are no official laws that require you to hold another country tax residency certificate. However, they always request to show it. It's proof that other country claims you to be their tax resident. Without it, it's much harder to prove that you are not a resident in home country. How can you claim you are not a resident in the home country if you don't hold any other country tax residency certificate? This is the question most EU countries would ask..
I don’t know what your home country is, but judging by your user name, I’m assuming Germany? As far as I know, Germany does not care about your tax residency anywhere else. All they care about is whether you still have ties to Germany, like an apartment you have access to, even though you don’t spend any time there. The Germany-UAE tax treaty explicitly states that Germany will continue to tax your worldwide income if you are a resident of both Germany and the UAE. You only get a credit for taxes paid in the UAE (they must have had a good laugh when they drafted that treaty). So even if you spend 230 days in the UAE and get a tax residency certificate - if you still have an apartment in Germany, Germany WILL tax your worldwide income. So how would that certificate change anything at all? It wouldn’t be proof that you really have cut all ties with Germany. And with Panama, there is not even a tax treaty that would cover personal income tax.

I have met some Germans as a nomad, and only one person told me that he had to prove to the German tax office that he had been out of the country for more than 182 days in that year. But he didn’t have to present a tax certificate, local receipts and boarding passes were more than good enough. He was also from the Southwest, so maybe it’s a thing there?
All other nomads I’ve spoken to simply left Germany, cut all ties and never heard from them again.

Say you have left your home country, cut all ties, moved to the UAE, where you spend 170 days with your family every year. Your company is based there, your friends, gym membership, newspaper subscriptions. The rest of the year you spend traveling outside of your home country. You clearly have to strongest ties to the UAE. In practice, they would probably issue the certificate, but for the same or the argument, let’s assume they don’t: What difference would it make? You have no ties to your home country anymore, you have strong ties to the UAE, you never stay anywhere else long enough to become tax resident there instead.
The only case where I could imagine a certificate to be required is if your former country of residency explicitly required it. And that would be a formal, written requirement, which I called “category B.”

Which countries would that be? Italy?
 

Davis123

Active Member
Well blackmailing by suspending transactions is outrageous I think. Instead of EU getting this data on their own citizens travel history which they can get easily but punished other countries by suspending transactions between countries. This is the same way US did by introducing FATCA and blackmailing financial institutions to either hand over the data or face USD correspondence accounts suspension. Countries after countries fell over but US did not anything to stop NYC from money laundering as 2 biggest centers of money laundering are London and NYC for all global transactions even determined by their own agencies.
I agree for substance requirements but why ask UAE , Panama etc instead of simply looking over their own data. They have that data available on their systems for all PNR as suggested earlier. Sorry end of my discussion on this topic now. Good luck. Stay safe
 

JustAnotherNomad

Entrepreneur
What do you mean suspension transactions? I agree that there is bullying going on, but it doesn’t answer my question about the certificates...
 

isyet

Silver Member
I don’t know what your home country is, but judging by your user name, I’m assuming Germany? As far as I know, Germany does not care about your tax residency anywhere else. All they care about is whether you still have ties to Germany, like an apartment you have access to, even though you don’t spend any time there. The Germany-UAE tax treaty explicitly states that Germany will continue to tax your worldwide income if you are a resident of both Germany and the UAE. You only get a credit for taxes paid in the UAE (they must have had a good laugh when they drafted that treaty). So even if you spend 230 days in the UAE and get a tax residency certificate - if you still have an apartment in Germany, Germany WILL tax your worldwide income. So how would that certificate change anything at all? It wouldn’t be proof that you really have cut all ties with Germany. And with Panama, there is not even a tax treaty that would cover personal income tax.

I have met some Germans as a nomad, and only one person told me that he had to prove to the German tax office that he had been out of the country for more than 182 days in that year. But he didn’t have to present a tax certificate, local receipts and boarding passes were more than good enough. He was also from the Southwest, so maybe it’s a thing there?
All other nomads I’ve spoken to simply left Germany, cut all ties and never heard from them again.

Say you have left your home country, cut all ties, moved to the UAE, where you spend 170 days with your family every year. Your company is based there, your friends, gym membership, newspaper subscriptions. The rest of the year you spend traveling outside of your home country. You clearly have to strongest ties to the UAE. In practice, they would probably issue the certificate, but for the same or the argument, let’s assume they don’t: What difference would it make? You have no ties to your home country anymore, you have strong ties to the UAE, you never stay anywhere else long enough to become tax resident there instead.
The only case where I could imagine a certificate to be required is if your former country of residency explicitly required it. And that would be a formal, written requirement, which I called “category B.”

Which countries would that be? Italy?
I would like to share experiences about Germany. Laws are not always fully implemented in Germany. Traditional, unwritten laws are enforced. Let me convey our experience in December 2019. I had a student who wanted to leave Germany. We went to the state authority together. The answer we received in a nutshell: Close your registration in Germany. You must also indicate in which country and at which address you will continue your residence in this residence closure document. If you do not make any pension contributions in Germany for 2 years and you do not have insurance, we will officially close your tax residence. However, after 2 years, you must document that you have been residing in your new country for 2 years.
That's it. Laws and enforcement are different!
I would like to share experiences about Germany. Laws are not always fully implemented in Germany. Traditional, unwritten laws are enforced. Let me convey our experience in December 2019. I had a student who wanted to leave Germany. We went to the state authority together. The answer we received in a nutshell: Close your registration in Germany. You must also indicate in which country and at which address you will continue your residence in this residence closure document. If you do not make any pension contributions in Germany for 2 years and you do not have insurance, we will officially close your tax residence. However, after 2 years, you must document that you have been residing in your new country for 2 years.
That's it. Laws and enforcement are different!
 
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