international tax-law income-tax
What is the maximum number of countries in which one can simultaneously be tax resident?
<p>Inspired by this Reddit thread and other stories of people working remotely from all over the world, apparently without giving too much thought to the legal implications,
<a href="https://www.reddit.com/r/UKPersonalFinance/comments/11wi578/working_abroad_remotely_and_uk_taxes/" rel="nofollow noreferrer">Working abroad remotely and UK taxes</a>:</p>
<blockquote>
<p>I work remotely abroad for most of the year (usually a new country every month). I'm registered as self employed in the UK and pay 40% on tax. I've taken the UK tax residency test on the Gov UK website and it states i'm not a tax resident of the UK. I don't pay tax in any other country and the company i'm contracting for is not registered in the UK (its in the EU).</p>
<p>I'm confused about where / if i should be paying tax.</p>
</blockquote>
<p>I am wondering - what is the worst-case scenario? Could one hypothetically end up in a situation in which two (or more) countries all simultaneously consider one to be <a href="https://en.wikipedia.org/wiki/Tax_residence" rel="nofollow noreferrer">tax resident</a> for the same year, and each demand their headline rate of income tax on the same income?</p>
<p>Tie-breaker - which combination of simultaneous tax residencies would result in the highest total marginal rate of income tax? Is a figure of over 100% possible?</p>
<p>For full credit, answers should take into account:</p>
<ul>
<li>The tax residency rules of each country (obviously!)</li>
<li>All relevant <a href="https://en.wikipedia.org/wiki/Tax_treaty" rel="nofollow noreferrer">double tax treaties</a></li>
<li>All instances where one country would offer a tax credit/refund based on tax paid in any of the others, based on its own domestic law, in the absence of a treaty.</li>
</ul>
<p>You may assume any nationality or level of income you like as long as you state it in your answer.</p>
<hr />
<p>After undertaking a small amount of initial research, it turns out that owning or leasing a private residential property is a very easy way of acquiring tax residency in a large number of countries. On reflection, however, since this question was inspired by digital nomads, let's also assume that the individual in question is reasonably nomadic and owns or leases a private residential property for their personal use in at most one country.</p>

<p>Sample answer:</p>
<ul>
<li>Be a US citizen - automatic US tax residency</li>
<li>Own a UK property and live there for 91 days to gain UK tax residency</li>
<li>Spend 60 days in India plus a total of 365 days over the previous 4 years</li>
<li>Spend 62 days in Norway, having been tax resident there the previous year. If I understand correctly, this status can be maintained indefinitely by spending 62 days there per year once first gained.</li>
<li>Spend 120 days in Paraguay</li>
<li>On the last day of the tax year, start working in the Philippines on an indefinite contract</li>
<li>Spend 183 days or more in Singapore during the prior tax year</li>
<li>Spend a total of 270 days in Mauritius over the current tax year and the previous two years (our calendar is getting pretty constrained at this point but I think this is still all technically possible)</li>
<li>Have access to a spare room that a friend informally keeps available for you in Germany</li>
<li>Be a member of the crew of a vessel registered in Mozambique</li>
<li>Have at least one essential connection to Sweden, having been tax resident there less than 5 years previously</li>
<li>Have a spouse who lives as a permanent resident in Spain and is somehow a contributing member of the Commonwealth Superannuation Scheme (triggering Australian tax residency)</li>
</ul>
<p>Total tax residencies: 13</p>
<p>Total marginal income tax rate after double tax treaties and reliefs for the tie break: no idea</p>
