Country A
Its own days, home, family or work test. A positive answer here does not cancel Country B.
Tax & Structuring
Tax residency across borders
Understand the factors that can determine where you are treated as tax resident — and why a simple day count may not be enough.
Tax residence is a facts-and-rules question, not a label you choose.
Tax residence is the status that usually decides which system looks at your worldwide income. Immigration permission is a different status. You can hold one without the other.
Residency on the Mobility hub compares immigration residence, tax residence and day counts together. This page stays with the tax test: domestic rules, ties, dual residence and how a treaty may break a tie.
The status
What tax residence usually does
In many systems, a person treated as tax resident is taxed on worldwide income, while a person who is not may be taxed only on income connected to that country. That is a description of a common pattern. It is not a rule you can apply to yourself. Some countries also use citizenship or another long-term connecting factor. Local rules vary.
Local law
Each country writes its own test
There is no shared international definition of tax residence that replaces domestic law. A treaty may decide which residence prevails when two countries both claim you, for the purposes of that treaty. It does not erase the domestic tests. Start with the statute or the local practice, then ask whether a treaty is relevant.
Days
Time spent in a country is often one factor. The number, and what else is required, is local.
Home
A place available to live can matter even in a year when you are often somewhere else.
Family
Where a spouse, partner or children live can be part of a test, or of a treaty tie-breaker.
Work
Employment, self-employment and board roles can connect you to a country’s tax system.
Other ties
Economic links, habitual abode and formal registration appear in some systems and not in others.
Time
Day counts are evidence, and only part of many tests
People often start with days because days can be counted. Many tests use days alongside a home, family or work. The threshold, if there is a single number, is national. A year that looks comfortable against a number you have heard is still a year that needs the full local test.
A residency day tracker keeps the record. It does not apply the law.
Do not rely on a single day threshold without checking the full local test.
A place to live
An available home can be its own connecting factor
Some tests ask whether you have a home available, not only whether you slept there. A property you keep, a lease that continues, or a room that remains yours can be relevant. Selling or ending a lease is a fact. Whether it ends tax residence is a legal question.
Family
Where the family lives can pull a test in a different direction
A spouse, civil partner or children living in a country can be part of a domestic test, and can also matter when a treaty looks at the centre of a person’s life. Family arrangements change. The tax question should be asked again when they do.
Work
Employment, a business or a board role is a tie of its own
Where you perform work, who employs you, and whether you direct a company from a country can each be relevant to personal tax residence. They can also create a separate question for the business. Personal residence and company residence are related facts. They are not the same conclusion.
Overlap
Two countries can both treat you as resident
Domestic tests do not check each other. It is possible to meet the conditions of more than one country in the same period, especially in a year of arrival or departure. Dual residence is a reason to look at a treaty, if one exists. It is not, by itself, a result.
Country B
A different statute, often a different tax year. Both can be engaged before any treaty is opened.
Treaties
A treaty may decide which residence prevails
Where a treaty applies, residence conflicts are often worked through in a sequence. The ideas below are conceptual. They are not a checklist you can score, and they are not article numbers. The order and the wording depend on the treaty.
How treaties allocate taxing rights more widely is on double-tax treaties.
01
Permanent home
02
Centre of vital interests
03
Habitual abode
04
Nationality
05
Mutual agreement
Permanent home, the centre of vital interests and habitual abode are ways a treaty may describe where life is based. Nationality can be a later factor. Mutual agreement is a process between the two tax authorities when the earlier tests do not settle the question. None of this applies itself.
Departure
Leaving can matter as much as arriving
The final year, the date you leave, ties that continue, and any departure filing or deregistration are part of the same story. A large sale, a bonus or a dividend in that year can fall under rules that are different from a settled year abroad. Do not make a transaction solely to fit a date.
Arrival
Arrival often brings a registration, not only a new address
A local tax number, a municipal or tax registration, and the first filing period are practical questions in many countries. When tax residence begins can differ from the date on a visa or a lease. Ask both dates.
Records
Residence positions are easier to explain when the facts are written down
- Travel records
- Housing
- Employment
- Family
- Bills
- Registrations
Travel history, leases, employment contracts, evidence of where family lived, utility bills and registration letters are the usual file. Keep them by tax year.
Watch for
Assumptions that skip the actual test
- Assuming 183 days solves everything
- Confusing a visa with tax residence
- Ignoring home, family and work
- Keeping no records of the year
- Assuming residence in the old country ends on the day of the flight
A familiar day count is not a universal test. Days are one factor, and the rest of the local rule still has to be read.
Due diligence
Questions worth asking before you rely on a residence position
01Which countries could treat me as tax resident this year?
List every country where you have days, a home, family or work. Ask the question for each of them.
02What is the domestic test in each of those countries?
Ask for the local rule, including factors other than days. Do not import a test from a country you used to live in.
03How are days counted?
Ask what counts as a day, and which days are ignored, if any. A tracker is a record. It is not the test.
04Does an available home matter?
Ask whether a house or apartment you can use is relevant even if you are often away.
05Does where my family lives matter?
Ask whether a spouse, partner or children are part of the domestic test.
06Does my work matter?
Ask whether employment, a business or a board role is a connecting factor where you do that work.
07Could I be resident in more than one country?
Ask whether two domestic tests could both be met in the same period.
08If so, does a treaty tie-breaker apply?
Ask whether a treaty between those countries has a residence article, and which facts it looks at. This page does not apply one.
09What happens in the year I leave?
Ask whether the country splits the year, keeps you resident for the whole year, or uses another departure concept.
10What happens in the year I arrive?
Ask when the new country may start to treat you as resident, and what the first filing period is.
11Do I need to register or deregister?
Ask whether a tax number, a departure filing or a local registration is part of the process.
12Which ties continue after I leave?
Ask whether a home, a role or family remaining behind can keep a connection alive.
13How does this differ from my visa or permit?
Ask the tax question separately from immigration status. The broader comparison is on the residency page under Mobility.
14What evidence should I keep?
Ask for a list covering travel, housing, work and family, kept as you go.
15Does residence affect my estate or my company?
Ask whether a change of tax residence changes how property, a will or a company is looked at. Those topics have their own pages.
16What should be reviewed next year?
Ask which change of days, home or work would make this year’s answer stale.
Professional support
When a tax residence opinion may be appropriate
This page explains the factors. It does not decide where you are resident. Advice from a qualified tax adviser in each country that might claim you may be appropriate in a year of arrival, departure, dual residence, or when a treaty tie-breaker might be relevant.
Compare tax residency providers
Tax residency advice depends on more than counting days
Tax residence is determined under domestic tax law and, in some cases, modified by treaty rules.
Compare cross-border tax providers by statutory residence-test capability, day-count analysis, personal ties, treaty tie-breakers, dual-residence support and pre-arrival or departure planning.
A provider that is suitable for a straightforward US expat return may not be appropriate for a complex dual-residency case involving several homes, businesses, family ties and treaty questions.
Start with the question
What tax residency issue are you dealing with?
What to compare
The right provider depends on how complicated your residence position is
01
Domestic residence tests
Can they interpret the rules in the countries involved?
02
Day counting
Can they analyse the relevant counting rules correctly?
03
Personal ties
Home, spouse, children, work and economic connections.
04
Dual residence
Can they handle cases where two countries claim residence?
05
Treaty tie-breakers
Can they analyse permanent home, vital interests, habitual abode and other treaty tests?
06
Arrival / departure
Can they advise before the move rather than after year end?
07
Compliance
Can they coordinate filings where more than one country is involved?
08
Evidence
Can they help identify what records should be retained?
Filter tax residency providers
5 providers listed for comparison.
Bright!Tax
US expat CPA tax service
US expat tax planning where foreign residence, domicile and treaty positions affect US compliance. Local-country advice may still need another professional.
- Best aligned with
- Americans living abroad, dual citizens and international US taxpayers
- Global reach
- High
- Residency analysis
- US cross-border context
- Statutory tests
- US expat tests
- Personal ties
- Limited
- Treaty tie-breaker
- US treaty context
- Move planning
- Available
- Dual residence
- US and foreign
- Tax filings
- Core
- Service model
- Secure digital organizer
- Pricing model
- Starting prices published
US-expat specialist. Local-country advice may require separate professionals.
Greenback Expat Tax Services
US expatriate tax specialist
US expat tax where foreign residence, the foreign earned income exclusion, the foreign tax credit and US treaty interaction matter. It does not replace local-country residence advice.
- Best aligned with
- US citizens and green-card holders living abroad
- Global reach
- High
- Residency analysis
- US expat context
- Statutory tests
- US expat tests
- Personal ties
- Limited
- Treaty tie-breaker
- US treaty context
- Move planning
- US moves
- Dual residence
- US and local
- Tax filings
- Core
- Service model
- Remote tax workflow
- Pricing model
- Published service pricing
Does not replace local-country tax-residence advice where non-US law decides the question.
MyExpatTaxes
Digital US expat tax platform
A digital platform for US expat filing, residency tests used in that filing, the foreign tax credit and treaty or totalization support. Complex non-US residence cases may need local advice.
- Best aligned with
- US citizens abroad seeking digital tax compliance
- Global reach
- High
- Residency analysis
- US expat context
- Statutory tests
- US filing workflow
- Personal ties
- Limited
- Treaty tie-breaker
- US treaty context
- Move planning
- Moderate
- Dual residence
- US and foreign
- Tax filings
- Core
- Service model
- Digital tax platform
- Pricing model
- Published tiered pricing
Primarily a US tax platform. Complex non-US tax-residence cases may need local advice.
Sable International
Cross-border tax residency and emigration advisory
Tax residence, tax emigration, restoring residency and cross-border personal tax. Strength in supported markets is not all-country coverage.
- Best aligned with
- Individuals moving between the UK, South Africa and other supported jurisdictions
- Global reach
- Medium-High
- Residency analysis
- Strong
- Statutory tests
- Strong
- Personal ties
- Supported markets
- Treaty tie-breaker
- Strong
- Move planning
- Strong
- Dual residence
- Strong
- Tax filings
- Strong
- Service model
- Adviser-led guidance
- Pricing model
- Quote in advance
Residency advice is strongest in supported markets. Do not treat it as an all-country service.
Vialto Partners
Global mobility tax and private client advisory
Individual tax residence, mobility tax and cross-border residence reviews for mobile people, executives and employers. Vialto does not determine a government residence status.
- Best aligned with
- Globally mobile individuals, executives, HNW families and employers
- Global reach
- Very high
- Residency analysis
- Strong
- Statutory tests
- Strong
- Personal ties
- Strong
- Treaty tie-breaker
- Strong
- Move planning
- Strong
- Dual residence
- Strong
- Tax filings
- Strong
- Service model
- Secure platform and alerts
- Pricing model
- Engagement-specific
Residence outcomes depend on domestic law, facts and treaty application. Vialto does not determine a government status.
Compare tax residency advisers
Short published facts only. Reach is not a country list, and these labels are not ratings.
A US filing platform is not the same proposition as a mobility adviser or a cross-border residence practice.
| Provider | Provider type | Best aligned with | Residency analysis | Statutory tests | Treaty tie-breaker | Move planning | Tax filings | View |
|---|---|---|---|---|---|---|---|---|
| US expat CPA | Americans living abroad, dual citizens and international US taxpayers | US cross-border context | US expat tests | US treaty context | Available | Core | View |
| US expat specialist | US citizens and green-card holders living abroad | US expat context | US expat tests | US treaty context | US moves | Core | View |
| Digital platform | US citizens abroad seeking digital tax compliance | US expat context | US filing workflow | US treaty context | Moderate | Core | View |
| Cross-border | Individuals moving between the UK, South Africa and other supported jurisdictions | Strong | Strong | Strong | Strong | Strong | View |
| Global mobility | Globally mobile individuals, executives, HNW families and employers | Strong | Strong | Strong | Strong | Strong | View |
| Provider | Provider type | Residency analysis | Treaty tie-breaker | Move planning | View |
|---|---|---|---|---|---|
| US expat CPA | US cross-border context | US treaty context | Available | View |
| US expat specialist | US expat context | US treaty context | US moves | View |
| Digital platform | US expat context | US treaty context | Moderate | View |
| Cross-border | Strong | Strong | Strong | View |
| Global mobility | Strong | Strong | Strong | View |
Bright!Tax
US expat CPA tax service
- Type
- US expat CPA
- Best aligned with
- Americans living abroad, dual citizens and international US taxpayers
- Residency analysis
- US cross-border context
- Statutory tests
- US expat tests
- Treaty tie-breaker
- US treaty context
- Move planning
- Available
- Dual residence
- US and foreign
Greenback Expat Tax Services
US expatriate tax specialist
- Type
- US expat specialist
- Best aligned with
- US citizens and green-card holders living abroad
- Residency analysis
- US expat context
- Statutory tests
- US expat tests
- Treaty tie-breaker
- US treaty context
- Move planning
- US moves
- Dual residence
- US and local
MyExpatTaxes
Digital US expat tax platform
- Type
- Digital platform
- Best aligned with
- US citizens abroad seeking digital tax compliance
- Residency analysis
- US expat context
- Statutory tests
- US filing workflow
- Treaty tie-breaker
- US treaty context
- Move planning
- Moderate
- Dual residence
- US and foreign
Sable International
Cross-border tax residency and emigration advisory
- Type
- Cross-border
- Best aligned with
- Individuals moving between the UK, South Africa and other supported jurisdictions
- Residency analysis
- Strong
- Statutory tests
- Strong
- Treaty tie-breaker
- Strong
- Move planning
- Strong
- Dual residence
- Strong
Vialto Partners
Global mobility tax and private client advisory
- Type
- Global mobility
- Best aligned with
- Globally mobile individuals, executives, HNW families and employers
- Residency analysis
- Strong
- Statutory tests
- Strong
- Treaty tie-breaker
- Strong
- Move planning
- Strong
- Dual residence
- Strong
Different residency providers suit different levels of complexity
Private-client tax residency advisory
For complex multi-country residence, HNW families and sophisticated planning. No provider of this model is listed in this comparison.
Global mobility tax advisory
For executives, employer-led moves and international assignments. Vialto Partners publishes this model.
Cross-border tax specialist
For specific country combinations and residence transitions. Sable International publishes this model, particularly for UK and South Africa routes.
Expat tax specialist
For nationality-specific compliance and foreign-residence interaction. Greenback Expat Tax Services and Bright!Tax publish US expat tax services.
Digital tax platform
For defined filing scenarios rather than complex residence disputes. MyExpatTaxes publishes a digital US expat tax platform.
Choose the provider model based on complexity and country combination — not simply convenience.
Common scenarios
Which situation is closest to yours?
Common situations
When the residence question is rarely one country
A year split between two homes
Days in both, and a home that may still be available in the country you left.
Family stays while you take a role abroad
Work in one place and family ties in another.
A board role kept after a move
Personal residence and where decisions for a company are made.
Returning for part of the year
A pattern of visits that may still meet a domestic test.
Tools
Related tools
These tools help with records and comparisons. They do not calculate tax.
Explore tax & structuring
Go deeper into a related topic
- International taxationWhy residence and source can both look at the same income.
- Double-tax treatiesHow a treaty may allocate rights once residence is in issue.
- Estate planningHow a longer personal connection can matter for an estate.
Unsure which country may treat you as tax resident?
Separate the domestic tests, the ties and any treaty before relying on a day count.
WiT Access provides general information and comparison resources. Tax residence depends on domestic law, personal facts, treaty provisions and individual circumstances. Nothing on this page constitutes tax, legal, financial or investment advice. Tax residence tests, day counts, tie-breakers and registration rules vary by jurisdiction.
WiT Access does not determine whether you are tax resident in any jurisdiction.
A residence permit, visa or citizenship does not by itself determine tax residence.
Day counting can be useful evidence but should not be treated as a substitute for professional analysis.