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Tax residence

Tax residence (or fiscal residence) is a key concept in international tax planning. It equally applies to individuals and businesses and constitutes a large part of the international wealth-management discussion recently. 

The question of the tax residence is especially relevant for the taxpayers living or working abroad or otherwise present internationally as it influences their respective tax liabilities. While in some countries tax residence of individuals is rather straight-forward, it can be quite tricky in the others. This can lead to situations where the same person is treated as tax resident in several countries and is therefore potentially liable to taxation over the same income in several jurisdictions. On the corporate scene fiscal residence is no less important. As with the individuals it determines which country and to which extent has taxing rights over the income of the companies. National criteria as well as internationally accepted concept of place of effective management and control are to be consulted and considered.

Current changes in the international tax legislation, reporting obligations and a trend to global mobility in general place an increased weight on tax residence issues. Careful planning and continuous supervision are recommended to ensure that individuals and corporations comply with the regulations of the various states involved.

MP Part provides our clients with the services aimed at limiting the risks related to tax residency, including: 

  • assessing the individual and corporate tax residency situation and implications associated with identified tax status;
  • risk analysis of the corporation’s management and control structure influencing tax residence interpretation, elaboration of the correction plan where necessary;
  • support in the cases of dual tax residence and tax residence migration.

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