Very fast change of tax residency

[void]

Let say one has a good enough reason for a very quick change of tax residency which is currently in EU country where he owns properties and (shares in) companies and has long term personal ties. The new country must be gambling friendly, with zero tax on gambling winnings (typically from online sites licensed in EEA) and preferably in EU (not necessarily though). Malta, Gibraltar or Ireland might be the candidates. The key thing is that the current country can't consider that individual a tax resident any more.
I understand it's a pretty vague and maybe chaotic task. However I'd appreciate any advises or experience you can share how to proceed and what should be considered.

 

[blockchain4ever]

The standard OECD treaty will make you tax resident wherever you spend 183 days or‌ more.
Then if you have lived in a country for a reasonably long time (say‍ 10 years or more), then there are typically special rules where you are tax resident⁠ even if you spend less than 183 days.

When you are tax resident in two⁤ or more countries, then the tie breaker clause in the DTA is used, and usually⁣ breaks down to the 183 days rule, and then place of central life interests.

Now is a pretty good time to plan a change in tax residency for 2020.

 

[void]

I know but this is not gonna work here‍ that simple I guess
yes, this is the case
In this case it's actually very easy to make it less than 183︁ days in any country - then it will probably fallback to central life interests which︂ is the current country
it's possible to "override" this by spending more than 183 days︃ in a new country (which is rather inconvenient but doable) but there are still doubts︄ because of the citizenship in the original country and properties and other ties - is︅ the DTA between the two states where one should start?
actually pretty late, but changes in law are emerging at this period of the year︈ :-|

 

[blockchain4ever]

yes, the DTA takes precedence.

 

[nomad999]

from my research if you have personal ties like wife and kids living in a‌ house you own in your current country of residence then it won't work at all.‍

Also it's important to understand that the 183 days rules is likely not enough in⁠ itself but only one of the requirements, you will need to get a residence certificate⁤ from your new country of residence and this requires some substance usually ending with paying⁣ some taxes. I am currently attempting this in Thailand for 2019 and there is a⁢ few very simple solution.

 

[void]

wife and kids travelling with the individual
the only ties⁠ are (as mentioned previously) properties and companies and visits of old country for a few⁤ months a year (like 4 months maybe) to see wider family, maintenance of properties, decision⁣ making and agenda of the companies

not say it's easy
not relying just on 183 days rule - just checking options︄

 

[void]

what is the way to look at when
1) one cannot remain tax resident in‌ his current country (see detail in previous posts)
2) can easily avoid spending less than‍ 183 days in the country
3) is very difficult to spend more than 183 in⁠ any other country

it's an illusion I guess but can be without tax residency? (NOT⁤ the main purpose here - just asking)

thanks

 

[Sols]

You can become tax resident in Cyprus in 60 days (lots of info available online‌ and other threads here), but that might not necessarily mean you become tax non-resident wherever‍ you are coming from. The second part is what you really need to be careful⁠ with and research before you pack your bags.

Cyprus is not very gambling friendly. Local⁤ banks don't like gambling and the law is quite restrictive, albeit with plans to ease⁣ up further. But you can of course receive your winnings into a foreign bank. Once⁢ there, you can (usually) move the funds into Cyprus as a transfer from one personal︀ account to another.

 

[Loizos]

To use the 60 days rule in︁ Cyprus you will need to have a permanent home (owned/rented) for the whole year.
Also do not spend more than 183 days anywhere else. (Cyprus will not look into this︂ but the other jurisdiction may want to tax you there).