european-union tax-law
OECD model tax convention: changing residence mid-month
<p><a href="https://www.oecd.org/ctp/treaties/articles-model-tax-convention-2017.pdf" rel="nofollow noreferrer">OECD model tax convention</a> and its <a href="https://www.oecd.org/berlin/publikationen/43324465.pdf" rel="nofollow noreferrer">commentary</a> serves as a basis for many Double Taxation Agreements between European countries. How, typically, is a person P taxed according to the tax convention in the following case:</p>
<ul>
<li>P is a resident of country A according to the convention from Jan 1 until Aug 15</li>
<li>then, from Aug 15 until Dec 31 they are a resident of country B</li>
<li>they derive income from employment which is exercised in the corresponding states (A until mid-August, B afterwards)</li>
<li>they receive salary at the end of the month (ie. Aug 31)</li>
</ul>
<p>Should the August salary be taxed only by the country B (which is the country where P is a resident when he receives the salary) or half-half between A &amp; B, as P already earned half of their August income when they became a resident of B?</p>

<h2>Individuals generally operate on a cash basis for taxation</h2>
<p>When you are paid is when the tax liability occurs.</p>
<p>Larger businesses operate on an accruals basis; when they become entitled to the income is when the tax liability occurs irrespective of when (or if) they get paid.</p>
