Tax Residency Planning Lawyers

PBL Law Group is the leading law firm for establishing & defending your optimal tax residency status.

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Who Our Tax Residency Planning Lawyers Help

Perpetual Travelers

We create a defensible framework to establish a clear tax residency in a premier low-tax jurisdiction.

Global Founders

We manage your global travel to prevent accidental tax residency in multiple countries.

Mobile Asset Owners

We structure the ownership of your high-value mobile assets to align with your optimal tax residency.

High-Tax Expats

We provide a clear legal strategy to formally sever your tax residency & defend against trailing tax claims.

Tax Residency Disputes

We provide elite counsel & defence during tax residency audits, disputes & formal investigations.

End-to-End Tax Residency Planning Services

Residency Establishment

We create a robust legal framework to establish a clear, defensible tax residency in a premier jurisdiction.

Residency Severance

We manage the formal severance of your ties to a high-tax jurisdiction, ensuring a clean & defensible legal exit.

Tax Treaty Application

We apply tax treaty tie-breaker rules to legally resolve dual residency conflicts in your favour.

Residency Audit Defence

We provide elite counsel & representation during tax residency audits, disputes & litigation with global tax authorities.

Domicile & Estate Tax Planning

We advise on the complex legal concept of domicile to mitigate your long-term inheritance & estate tax exposure.

Day-Count Management

We provide a proactive framework to manage your global travel & ensure your compliance with critical day-count rules.

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Our Tax Residency Planning Process

1

Global Risk Audit

We analyse your global footprint to identify your critical tax residency vulnerabilities.

2

Defensible Blueprint

We design a bespoke legal blueprint to establish, sever or defend your desired tax residency status.

3

Building Your Case

We execute the strategy, managing all declarations & structuring to build a robust, evidence-based case.

4

Ongoing Defence

We proactively manage your residency so it remains secure & ready to withstand any scrutiny.

Elite Counsel for High-Stakes Residency Planning

Your tax residency is the foundation of your global financial life. An ill-planned or poorly defended residency status can lead to catastrophic tax consequences. Architecting & defending this status requires elite, multi-disciplinary legal counsel.

PBL Law Group provides this complete, partner-led counsel. Our team of Raea KhanMark LeaGeorge Halikiotis, & Anthony Watson unites leading expertise in legacy planning, trust law, commercial structuring & complex tax. We provide the definitive strategic counsel required to architect a robust, defensible residency position & defend it against any challenge.

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Why Choose Our Tax Residency Planning Lawyers

1

Defensible by Design

We proactively build a legally robust, evidence-based strategy to establish, sever or defend your tax residency.

2

Elite Audit Defence

Our partner-led advice successfully defends your residency status against any global tax authority challenge.

3

Holistic Integration

We seamlessly integrate your residency strategy with your business, trust & long-term legacy structures.

4

Proactive Management

Our strategic framework manages your global travel & day-counts, delivering total compliance & clarity.

Visit Our Private Client Lawyers

We provide expert private client advice internationally. Meet with our team at our CBD offices in Singapore or Sydney.

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Beyond the Day Count

Relying solely on the “183-day rule” is a critical error. Tax residency is a complex, fact-based test where authorities analyse your global ties to claim you as a resident, even if you are under the day-count. This is the primary trap for the global nomads.

PBL Law Group provides a definitive, holistic strategy. We go beyond day-counts, architecting a robust, evidence-based case around your centre of vital interests to create a legally defensible residency position that can withstand intense scrutiny.

When the Audit Letter Arrives

A tax residency audit is not a financial enquiry; it is a high-stakes legal challenge. Tax authorities will aggressively dispute your status with the sole aim of subjecting your entire global wealth to their tax system. Facing this without elite legal counsel is an unacceptable risk.

We are your strategic defenders. Our team, led by the most respected tax dispute advisors, provides the elite counsel required to manage & win these disputes, protecting you from a catastrophic negative ruling.

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The Trailing Tax Trap

Simply leaving a high-tax country does not mean you have legally ceased to be a tax resident. Without a formal, strategic severance of your legal ties, tax authorities can pursue you for “trailing taxes” for years after your departure.

We architect a clean & defensible exit. We manage the complex legal process of formally severing your ties, creating a clear break that protects you from future claims by your former tax authority.

The Dual Residency Conflict

Being a resident of two countries simultaneously creates a dual-taxation nightmare. While a tax treaty provides a “tie-breaker” rule, winning this contest requires a sophisticated legal argument based on a carefully curated set of facts.

Our experts are masters of tax treaty application. We proactively structure your affairs & build the evidence-based case required to ensure the tie-breaker rules are resolved in your favour, legally assigning your residency to your preferred jurisdiction.

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FAQs for Tax Residency Planning

Tax residency is the legal status that gives a country the right to tax your worldwide income. It is determined by a complex series of tests, not just by your citizenship or where you spend the most time.

Tax residency determines your liability for income tax each year & can change. Domicile is your legal “homeland” which affects long-term inheritance & estate taxes, and is much harder to change.

It is a common guideline where spending over 183 days in a country can make you a tax resident. However, it is a dangerous oversimplification, as you can become a resident in far fewer days based on other factors.

Tax authorities conduct a “substance over form” analysis, looking at factors like your permanent home, family location & economic ties. These factors often override a simple day-count.

This occurs when you meet the domestic residency tests of two different countries in the same year. This creates a dual residency conflict that exposes you to double taxation on your global income.

This is a series of tests within a tax treaty used to resolve a dual residency conflict. It legally assigns residency to a single country, but winning the argument requires a sophisticated, evidence-based case.

Ceasing tax residency requires a formal severance of your legal & personal ties to a country. Simply leaving is not enough & can lead to “trailing tax” liabilities for years after your departure.

During an audit, a tax authority will conduct an intensive investigation into your global life, travel & finances. They will demand extensive evidence to support your residency position, making it a high-stakes legal process.

Yes, significantly. The location of your spouse & dependent children is a primary indicator of your “permanent home” & “centre of vital interests,” which can legally tie your tax residency to that country.

While theoretically possible, it is extremely difficult to achieve & sustain. Most individuals will retain a tax residency somewhere, and a poorly managed attempt can result in multiple countries claiming you as a resident.

Evidence can include everything from travel records & property ownership details to club memberships & family arrangements. A key part of the strategy is curating this evidence to build a strong, coherent case.

Owning property is a significant connecting factor, but it does not automatically make you a tax resident. However, it is a key piece of evidence that a tax authority will use when building a case against you.

Your domicile determines which country’s laws apply to your estate upon death & can trigger significant inheritance or estate taxes. This is a critical long-term issue that is distinct from your annual income tax residency.

These are taxes that a country can claim from you even after you have physically left. This happens when you have failed to formally & legally sever your tax residency according to their specific rules.

You should seek advice before you adopt a globally mobile lifestyle or as soon as your circumstances change. PBL Law Group’s proactive planning is the only way to prevent a future dispute with a tax authority.

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