Global Mobility Tax Lawyers & Compliance

What is tax residency?

Tax residency is the status that gives a country the right to tax your worldwide income. It is determined not by citizenship, but by factors such as physical presence (day-count rules) and personal or economic connections.

What is a day-count rule?

A day-count rule is used by most countries to determine tax residency based on the number of days you are physically present in the country. Exceeding a threshold, commonly 183 days, can automatically make you a tax resident.

Can I be a tax resident in multiple countries?

Yes. It is possible to be considered a tax resident in more than one country at the same time under their domestic laws, creating a significant risk of double taxation on global income.

What is Permanent Establishment (PE) risk?

Permanent Establishment risk is the risk that business activities carried out in a foreign country, such as working from a home office, could subject a company to local corporate taxes.

How does a tax treaty help avoid double taxation?

A tax treaty is an agreement between countries that provides tie-breaker rules to determine a single country of tax residence and establishes mechanisms to prevent the same income from being taxed twice.

What are the consequences of accidental tax residency?

The main consequence is that your entire worldwide income and assets may become subject to another country’s tax system, often resulting in severe and unexpected tax liabilities and penalties.

What is a social security agreement?

A social security agreement is a treaty between countries that coordinates social security contributions and benefits for individuals who live or work across borders, preventing double contributions.

Can I be forced to pay social security twice?

Yes. If you work in a country that does not have a social security agreement with your home country, you may be legally required to contribute to both systems at the same time.

How do you manage PE risk for a global business?

PE risk is managed by carefully structuring executive activities, authority, and contracts while abroad, supported by formal policies and clear operational protocols.

Does my physical location matter if my company is overseas?

Yes. Tax authorities increasingly focus on where work is physically performed, meaning your location can trigger personal tax residency and corporate PE risk.

What is a global mobility compliance framework?

A global mobility compliance framework is a customised set of rules, tracking systems, and protocols designed to proactively manage tax residency, PE risk, and cross-border compliance issues.

How do I track my travel days accurately?

Accurate tracking requires detailed records of all travel days, including arrival and departure days, which may count as full days for tax purposes.

What’s the difference between domicile and tax residency?

Tax residency determines where you pay income tax and can change frequently, while domicile represents your long-term legal home and mainly affects inheritance and estate taxes.

What is a tie-breaker rule?

Tie-breaker rules are found in tax treaties and apply when two countries claim tax residency. They use tests such as permanent home and centre of vital interests to assign residency to one country.

When should I seek advice on mobility tax?

You should seek professional advice before beginning a globally mobile lifestyle or making a major international move, as proactive planning is the only way to avoid costly tax issues.