Best country for a freelancer / digital nomad post-covid

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daniels27 said:
It only states

meaning

which is pretty common for all European countries. You can simply state you go to the US or whatever and that's it. Nobody cares.


Yes, but with all due respect, this is relating to DTAs. Most DTAs do have such clauses. But this only works bilaterally between two states in determining who can tax an individual, and then mainly for dividends, interest, etc. only as for active work, the general rule is that the country where work is done has the right to tax.
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I do not think it is great to lie in that case.

from the first link, page 7 - 30,31

(30) Ustanovenie ”žbydliska“ ako kritéria pre určenie rezidencie fyzickej osoby v zákone o dani z príjmov jezamerané najmä na fyzické osoby formálne a účelovo odhlásené z trvalého pobytu na území Slovenskejrepubliky za účelom vyhnutia sa ich daňovým povinnostiam na tomto území.Predmetné kritérium rezidencie fyzickej osoby je preto potrebné posudzovaÅ¥ a aplikovaÅ¥ najmä v kontextecieľa a účelu jeho zavedenia, t.j. zamedzenia vyhýbania sa daňovej povinnosti a medzinárodným daňovýmúnikom, pričom pri určení miesta ”žbydliska“ tohto daňovníka na účely zákona o dani z príjmov je potrebnéprihliadaÅ¥ na vÅ¡etky relevantné skutočnosti a okolnosti jednotlivých prípadov.

(30) The provision of "residence" as a criterion for determining the residence of a natural person in the Income Tax Act is aimed mainly at natural persons formally and purposefully deregistered from permanent residence in the territory of the Slovak Republic in order to avoid their tax obligations in this territory. The criterion of residence of a natural person in question must therefore be assessed and applied mainly in the context of the aim and purpose of its introduction, i.e. prevention of tax avoidance and international tax evasion, while when determining the place of "residence" of this taxpayer for the purposes of the Income Tax Act, it is necessary to take into account all relevant facts and circumstances of individual cases.

(31) Pre určenie miesta ”žbydliska“ daňovníka je relevantné zistiÅ¥ miesto, kde daňovník skutočne trvale býva, pričomje potrebné prihliadaÅ¥ nielen na možnosÅ¥ trvalo dostupného bývania daňovníka na určitom území,ale aj na podmienky a skutočné dôvody zdržiavania sa daňovníka na tomto území, okolnosti skončenia predchádzajúceho trvalého pobytu, okolnosti zmeny bydliska, či Å¡tátnu prísluÅ¡nosÅ¥ daňovníka.

(31) In order to determine the place of "residence" of a taxpayer, it is relevant to determine the place where the taxpayer actually permanently resides, taking into account not only the possibility of permanently available housing for the taxpayer in a certain territory, but also the conditions and real reasons for the taxpayer's stay in this territory, the circumstances of the termination of the previous permanent residence, the circumstances of the change of residence, or the taxpayer's nationality.

31 - the last word translated as nationality, but "Å¡tátnu prísluÅ¡nosÅ¥" is citizenship, just for correctness.
 
I do not think it is great to lie in that case.︀

from the first link, page 7 - 30,31

(30) Ustanovenie „bydliska“ ako kritéria pre určenie︁ rezidencie fyzickej osoby v zákone o dani z príjmov jezamerané najmä na fyzické osoby formálne︂ a účelovo odhlásené z trvalého pobytu na území Slovenskejrepubliky za účelom vyhnutia sa ich daňovým︃ povinnostiam na tomto území.Predmetné kritérium rezidencie fyzickej osoby je preto potrebné posudzovať a aplikovať najmä︄ v kontextecieľa a účelu jeho zavedenia, t.j. zamedzenia vyhýbania sa daňovej povinnosti a medzinárodným daňovýmúnikom,︅ pričom pri určení miesta „bydliska“ tohto daňovníka na účely zákona o dani z príjmov je︆ potrebnéprihliadať na všetky relevantné skutočnosti a okolnosti jednotlivých prípadov.

(30) The provision of "residence" as︇ a criterion for determining the residence of a natural person in the Income Tax Act︈ is aimed mainly at natural persons formally and purposefully deregistered from permanent residence in the︉ territory of the Slovak Republic in order to avoid their tax obligations in this territory.︊ The criterion of residence of a natural person in question must therefore be assessed and︋ applied mainly in the context of the aim and purpose of its introduction, i.e. prevention︌ of tax avoidance and international tax evasion, while when determining the place of "residence" of︍ this taxpayer for the purposes of the Income Tax Act, it is necessary to take︎ into account all relevant facts and circumstances of individual cases.

(31) Pre určenie miesta „bydliska“️ daňovníka je relevantné zistiť miesto, kde daňovník skutočne trvale býva, pričomje potrebné prihliadať nielen na‌ možnosť trvalo dostupného bývania daňovníka na určitom území,ale aj na podmienky a skutočné dôvody zdržiavania‍ sa daňovníka na tomto území, okolnosti skončenia predchádzajúceho trvalého pobytu, okolnosti zmeny bydliska, či štátnu⁠ príslušnosť daňovníka.

(31) In order to determine the place of "residence" of a taxpayer, it⁤ is relevant to determine the place where the taxpayer actually permanently resides, taking into account⁣ not only the possibility of permanently available housing for the taxpayer in a certain territory,⁢ but also the conditions and real reasons for the taxpayer's stay in this territory, the︀ circumstances of the termination of the previous permanent residence, the circumstances of the change of︁ residence, or the taxpayer's nationality.

31 - the last word translated as nationality, but "štátnu︂ príslušnosť" is citizenship, just for correctness.
 
Yes, but those are the normal anti abuse rules for people deregistering in their home‌ country. We had long discussions about many different countries. Under no circumstance are they going‍ to tax your Paraguay-born kid that never lived in Bratislava.
 
daniels27 said:
Yes, but those are the normal anti abuse rules for people deregistering in their home country. We had long discussions about many different countries. Under no circumstance are they going to tax your Paraguay-born kid that never lived in Bratislava.
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As I said before, I was asked vague and general questions. If the country and circumstances are specific, the usefulness and, more importantly, the legality of some solution can be determined.
I remain with my first post in thread. If average digital nomad wish to get the residency in other country - in MY opinion, Paraguay and Georgia are his best shots in terms of costs of setup and maintanence, the simplicity of the process BUT I definetely do not know all solutions, and I am not the smartest and most experienced member of this forum.
 
As I said before, I was asked vague and general questions. If the country and⁤ circumstances are specific, the usefulness and, more importantly, the legality of some solution can be⁣ determined.
I remain with my first post in thread. If average digital nomad wish to⁢ get the residency in other country - in MY opinion, Paraguay and Georgia are his︀ best shots in terms of costs of setup and maintanence, the simplicity of the process︁ BUT I definetely do not know all solutions, and I am not the smartest and︂ most experienced member of this forum.
 
Sorry, I don't read Slovak. Even if Slovakia had such a rule (which I doubt,‌ never heard that Slovakia has citizenship-based taxation if you don't take up tax residency elsewhere),‍ it would be a Slovak law, not a general law.

If this was a OECD⁠ directive that all OECD countries have to transpose into national law, then it should be⁤ easy for you to find the equivalent law in e.g. the UK, so that we⁣ can all read it.

Most likely, as @daniels27 also mentioned, you were quoting something from⁢ the OECD DTA "master template". But DTAs cannot create new tax obligations, they can only︀ limit existing ones that exist under national law.
Article 4 always starts with a condition︁ that someone is tax resident in both contracting states under their respective national law -︂ and then you can look at things like citizenship. But if you're not tax resident︃ under national law, the treaty cannot create a tax residency based on your citizenship.

And there are lots of countries that won't tax you just for becoming resident. You can︄ take the Baltics as an example, or Cyprus if you stay less than 60 days.︅
The main advantage with Paraguay is that they'll probably just leave you alone.
But I︆ can't imagine e.g. Cyprus coming after you if you're a pure paper resident and you︇ can prove you spend less than 60 days per year there.

On the other hand,︈ if some other country decides to tax you, your Paraguay paper residency won't be worth︉ much since they have very few tax treaties.
It's not bad, but it's not the︊ great get-out-of-jail-free card some people think it is.
 
Why would⁤ they have to be able to contact you, if you finish all your tax paperwork⁣ there and move away?
BTW: No one stops you from informing them that you haven't⁢ decided yet, changing your mind after arriving in the second country, or telling them that︀ your future country is DPRK. Even if only for privacy reasons. It doesn't matter what︁ they think, they won't tax you if you aren't residing there anymore, or nor have︂ any connections like property or family. Even when renewing your passport in the future at︃ some embassy, you can ask them to write 'no permanent residence' in your passport. That's︄ a fact, I did it myself and that's what it says in mine.

You can get a bank account as non-resident in most︈ places, the only disadvantage is that you might be taxed a little more on the︉ occurring interest than someone with a resident status. Hotel address is still accepted by many︊ banks.

Or you can just convert USDT when you need fiat, I could trade USDT︋ for cash with less than 2% spread in person in the last 4 countries I︌ have been without any issues. I even got a better rate than if I would︍ have used an ATM card or USD bills.

Brokerage accounts are becoming obsolete with DEFI,︎ you can trade stocks and options without any banksters skimming off money.

The 'never-ending travels'️ aren't so bad, you have 179 days to enjoy each country, you can choose the‌ best season to be in each place, and many of them are just a land‍ border away. If you don't want to carry your stuff around, there are storage solutions⁠ everywhere, which cost less than $30 per month (per ccm), or just ask your landlord⁤ to keep your stuff. Or just keep your apartment there, most landlords don't pay taxes⁣ and don't report you living there anyway. Or just hire a guy with a Lexus⁢ to fill it up with your stuff and bring you to your next destination for︀ $100 or so.

So yes, living tax free as a PT is possible, if you︁ know what you are doing. And are a non US person.
 
Beware. Many countries are going to tax you way sooner than‍ that. Switzerland is 30 day when working and 90 days otherwise. US substantial presence test⁠ assist kicks in faster if you keep doing it year by year.
 
Yep. I⁠ tend to avoid the US and EUSSR, I haven't known that 90 days thing about⁤ Switzerland though, I'll keep it in mind. Thanks for the info!

In Asia, one just⁣ needs to be aware of the details .

Some countries count the >180 days per⁢ calendar year with a new beginning on January 1st,
some (like VN) calculate >180 days︀ in the last 12 months, without a cut off at the end of the year.︁

In reality, one is seen as a tourist enjoying a long holiday, without any questions︂ asked.

In the case of crypto holding/trading: As many of those countries don't recognize or︃ regulate crypto (trading) at all, that's just risk mitigation. It's a legal precaution/prudential advice that︄ aims to minimize legal risk and avoid potential liability or accusations of wrongdoing, just sort︅ of defensive compliance" or "preemptive compliance," where a person or entity takes extra measures to︆ ensure they are not violating laws or inciting others to violate laws, even if the︇ legal requirements are unclear, debatable, grey, or non-existent (credit to jafo for that).
 
In Germany too. Until one day, they investigate you.‍ It is unlikely as it is in Asia. But if they catch you, they will⁠ add the charges of tax evasion.

Humans are like money. It is just much more⁤ difficult to find something that he moving every couple of days.
 
JustAnotherNomad said:
Sorry, I don't read Slovak. Even if Slovakia had such a rule (which I doubt, never heard that Slovakia has citizenship-based taxation if you don't take up tax residency elsewhere), it would be a Slovak law, not a general law.

If this was a OECD directive that all OECD countries have to transpose into national law, then it should be easy for you to find the equivalent law in e.g. the UK, so that we can all read it.

Most likely, as @daniels27 also mentioned, you were quoting something from the OECD DTA "master template". But DTAs cannot create new tax obligations, they can only limit existing ones that exist under national law.
Article 4 always starts with a condition that someone is tax resident in both contracting states under their respective national law - and then you can look at things like citizenship. But if you're not tax resident under national law, the treaty cannot create a tax residency based on your citizenship.

And there are lots of countries that won't tax you just for becoming resident. You can take the Baltics as an example, or Cyprus if you stay less than 60 days.
The main advantage with Paraguay is that they'll probably just leave you alone.
But I can't imagine e.g. Cyprus coming after you if you're a pure paper resident and you can prove you spend less than 60 days per year there.

On the other hand, if some other country decides to tax you, your Paraguay paper residency won't be worth much since they have very few tax treaties.
It's not bad, but it's not the great get-out-of-jail-free card some people think it is.
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You got me with the "general law". You confused your position in this debate. I do not have to look up anything for you (I already did), especially when all your value provided in this debate is "But I can't imagine" or "if some other country decides to tax you, your Paraguay paper residency won't be worth much"
No, the document "most likely" discusses determining tax residency and applying for DTTs.
 
You got︌ me with the "general law". You confused your position in this debate. I do not︍ have to look up anything for you (I already did), especially when all your value︎ provided in this debate is "But I can't imagine" or "if some other country decides️ to tax you, your Paraguay paper residency won't be worth much"
No, the document "most‌ likely" discusses determining tax residency and applying for DTTs.
 
Let's keep it nice here please.

Look, the problem with such statements are that they⁢ only apply in very specific cases. And in general, it is just leading to confusion.︀

Look, this is toxic︂ and @cryptofriendly @JustAnotherNomad complained for a reason. We have had many idiots from EUSSR with︃ new accounts here asking for a tax residency (sometimes even with certificate) anywhere. The problem︄ is that taxation works the other way: you need to ensure the country you do︅ not like cannot tax you. They generally won't care much about what you bring if︆ your wife and kids are in school in your old home.

That's why they did︇ rectify the facts. You can advertise your residency here, but don't promise anything which in︈ the general case it is not (and this includes any claim of any sort that︉ any other country won't tax you).
 
cryptofriendly said:
Why would they have to be able to contact you, if you finish all your tax paperwork there and move away?
BTW: No one stops you from informing them that you haven't decided yet, changing your mind after arriving in the second country, or telling them that your future country is DPRK. Even if only for privacy reasons. It doesn't matter what they think, they won't tax you if you aren't residing there anymore, or nor have any connections like property or family. Even when renewing your passport in the future at some embassy, you can ask them to write 'no permanent residence' in your passport. That's a fact, I did it myself and that's what it says in mine.


You can get a bank account as non-resident in most places, the only disadvantage is that you might be taxed a little more on the occurring interest than someone with a resident status. Hotel address is still accepted by many banks.

Or you can just convert USDT when you need fiat, I could trade USDT for cash with less than 2% spread in person in the last 4 countries I have been without any issues. I even got a better rate than if I would have used an ATM card or USD bills.

Brokerage accounts are becoming obsolete with DEFI, you can trade stocks and options without any banksters skimming off money.

The 'never-ending travels' aren't so bad, you have 179 days to enjoy each country, you can choose the best season to be in each place, and many of them are just a land border away. If you don't want to carry your stuff around, there are storage solutions everywhere, which cost less than $30 per month (per ccm), or just ask your landlord to keep your stuff. Or just keep your apartment there, most landlords don't pay taxes and don't report you living there anyway. Or just hire a guy with a Lexus to fill it up with your stuff and bring you to your next destination for $100 or so.

So yes, living tax free as a PT is possible, if you know what you are doing. And are a non US person.
Click to expand...
A few posts ago your biggest problem with Paraguay was
"Paraguay looks interesting, but I remember something about banking issues regarding inward/outward transfers,"

Glad you solved it already for yourself with DEFI and USDT.
 
A few posts ago⁠ your biggest problem with Paraguay was
"Paraguay looks interesting, but I remember something about banking⁤ issues regarding inward/outward transfers,"

Glad you solved it already for yourself with DEFI and USDT.⁣
 
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