tax-residency-primer

Tax Residency Primer Skill

Cross-border tax is where confident people make expensive mistakes, because moving

countries can leave you tax-resident in two places at once, owing tax you didn't expect,

or missing a treaty benefit that would have saved thousands. This skill does exactly one

thing well: it orients you — the factors that determine residency, the traps to watch,

and the specifics to pin down — so that your conversation with a qualified cross-border

tax professional is short and productive. It is emphatically not tax advice, gives no

figures or filings, and its main output is often "here's why you need a professional, and

here's exactly what to ask them."

What This Skill Produces

• A residency-question map: the factors tax systems actually use (days present,

permanent home, centre of vital interests, domicile, the split-year rules) framed as

questions to answer for your situation — not conclusions

• The trap list: dual residency, double taxation, the year-of-move split, exit taxes,

reporting of foreign accounts/assets, and remote-work-from-abroad complications — so

none ambush you

• A document/fact checklist: what to gather before filing or before seeing an adviser

(travel dates, home ownership/rental, income sources and countries, prior-country

status)

• The questions for a professional: a tight, specific list so a cross-border tax

adviser can resolve your situation efficiently — plus how to find one

Required Inputs

Ask for (if not already provided):

• The countries involved (moved from → to) and the date of the move
• The rough shape of income (employment, self-employment, investments, foreign income,

remote work for a foreign employer) — categories only, no amounts needed

• Ties to each country (home owned/rented, family, days spent, prior residency)
• What's prompting the question (an approaching filing deadline, a job, uncertainty)

Framework

1. Frame residency as questions, never a verdict. Tax residency turns on factors like

days present (and the specific counting rules), where your permanent home is, your

centre of vital interests, and sometimes domicile — combined differently in every

country. The skill lays these out as questions to answer with an adviser; it does not

declare you resident anywhere.

1. Surface the dual-residency and treaty reality. You can be resident in two countries

simultaneously; double-tax treaties then have "tie-breaker" rules and relief

mechanisms — but they must be claimed correctly. Flag that this is likely in a move

year and that the treaty (if one exists) matters, without interpreting it.

1. Name the year-of-move and remote-work traps. The move year is the messiest —

split-year treatment, part-year residency, income sourced before/after the move. And

working remotely from a new country for an old-country employer creates residency,

payroll, and even permanent-establishment questions people rarely anticipate. Flag

these prominently.

1. Build the fact pack. The adviser will need: precise travel/presence dates, home

status in each country, income types and their source countries, prior tax status,

and any foreign-account/asset reporting obligations (which carry heavy penalties if

missed). Gathering these in advance turns an expensive open-ended consult into a

focused one.

1. Route to a qualified professional — and say why. Cross-border tax genuinely needs

an expert (a cross-border/expat tax adviser or accountant covering both countries).

The skill's honest deliverable is a well-prepared client with the right questions, and

the clear message that DIY here risks real money and legal trouble.

Output Format

## Your residency questions (to resolve with an adviser — not answered here)
[Days/presence · permanent home · centre of vital interests · domicile · split-year —
as questions for your situation]

## Traps to raise
[Dual residency & treaty tie-breakers · double-taxation relief · year-of-move split ·
exit taxes · foreign-account/asset reporting · remote-work-from-abroad]

## Fact pack to gather (before filing / before the adviser)
[Travel dates · home status per country · income types & source countries · prior
status · reporting obligations]

## Questions for a cross-border tax professional
[The tight, specific list · how to find a suitable adviser]

⚠ This is NOT tax advice and contains no figures or filings. Cross-border tax must be
handled by a qualified professional for your specific countries and situation.

Quality Checks

• [ ] Residency is framed entirely as questions to resolve with a professional — zero

residency verdicts or filing guidance

• [ ] The dual-residency/treaty and year-of-move/remote-work traps are surfaced
• [ ] A concrete fact pack to gather is provided
• [ ] The output routes clearly to a qualified cross-border adviser and says why DIY is risky
• [ ] The not-tax-advice line is present and unambiguous

Anti-Patterns

• [ ] Do not give tax advice, figures, filings, or a residency determination — orient

only, and route to a professional; this is the hard rule

• [ ] Do not interpret a specific treaty or country's rules as settled — flag that they

apply and must be handled by an expert

• [ ] Do not understate the risk — missed foreign-asset reporting and double taxation

carry real penalties

• [ ] Do not skip the remote-work-from-abroad trap — it's increasingly common and rarely

anticipated

• [ ] Do not send the user off without a prepared question list — a focused consult is

the whole value

Related

[[arrival-setup]] for the tax-number step; [[credit-from-scratch]] and

[[healthcare-system-primer]] for the other newcomer systems; [[micro-retirement-planner]]

if the move is a career break; [[financial-model-narrative|budget-variance-analysis]]

neighbors for business finances — but a professional owns the tax itself.