@NewHorizonsParaguay seems competent and well connected. I had a good conversation with him and decided to proceed later this new year, early spring I believe. I will report my progress here.
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As mentioned, I get your point. But it is mainly about how to satisfy banking monkeys, rather than about the tax liabilities itself.
Very interesting. Which law regulates that?
@JustAnotherNomad, he is referring to the bank monkeys that need to do some CRS reporting. If you cannot give them anything else, they will ask for the tax id of your nationality. Happens quite often in some places. There are in very limited cases maybe such laws, but not really. Some countries want a proof of tax residency elsewhere in order to release you from their tax liability. But also that only happens in very few EUSSR countries.
You don't need tax residency for CRS reporting. Banks will usually ask for an address and a utility bill, not a tax residency certificate.
Of course never enough. Which one you like the most? Have you tried Peru?A fewNever enough
Sorry, I do not know if this is your standard communication style, but you expect specific answers to vague and general questions. (In what cases would it be an advantage to have tax residency in Paraguay?)
I choose to still continue in good faith, tho. Here you go.
https://www.financnasprava.sk/_img/...e/2020/2020.10.08_002_MZ_2020_MU_rezident.pdf
This sounds interesting. Can you maybe give us the exact article, where we have to look at?
Yes, page 7, 2.2 - 29,30,31,32
Here is the law forbidding not having residence in any country, as someone suggested in the discussion
https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/1998/253/
6 - 1
Here is the application of the OECD directives... which are part of the legislation in one way or another in all OECD member countries.
https://www.financnasprava.sk/_img/...e/2020/2020.10.08_002_MZ_2020_MU_rezident.pdf
page 13, 62 a,b,c,d
Your residency is determined in this order... permanent address, center of vital interests, habitual residence, CITIZENSHIP, bilateral agreements between countries.
None, each serves a specific purpose.
No and I don’t see why I should.
It only states
meaning
which is pretty common for all European countries. You can simply state you go to the US or whatever and that's it. Nobody cares. We had discussions in the past about this:
It is about consular protection etc. not mainly about taxes.
Yes, but with all due respect, this is relating to DTAs. Most DTAs do have such clauses. But this only works bilaterally between two states in determining who can tax an individual, and then mainly for dividends, interest, etc. only as for active work, the general rule is that the country where work is done has the right to tax.
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I can’t tell details of my specific situation, but I believe that it can be useful to many and the process is particularly convenient.
I do not think it is great to lie in that case.
from the first link, page 7 - 30,31
(30) Ustanovenie „bydliska“ ako kritéria pre určenie rezidencie fyzickej osoby v zákone o dani z príjmov jezamerané najmä na fyzické osoby formálne a účelovo odhlásené z trvalého pobytu na území Slovenskejrepubliky za účelom vyhnutia sa ich daňovým povinnostiam na tomto území.Predmetné kritérium rezidencie fyzickej osoby je preto potrebné posudzovať a aplikovať najmä v kontextecieľa a účelu jeho zavedenia, t.j. zamedzenia vyhýbania sa daňovej povinnosti a medzinárodným daňovýmúnikom, pričom pri určení miesta „bydliska“ tohto daňovníka na účely zákona o dani z príjmov je potrebnéprihliadať na všetky relevantné skutočnosti a okolnosti jednotlivých prípadov.
(30) The provision of "residence" as a criterion for determining the residence of a natural person in the Income Tax Act is aimed mainly at natural persons formally and purposefully deregistered from permanent residence in the territory of the Slovak Republic in order to avoid their tax obligations in this territory. The criterion of residence of a natural person in question must therefore be assessed and applied mainly in the context of the aim and purpose of its introduction, i.e. prevention of tax avoidance and international tax evasion, while when determining the place of "residence" of this taxpayer for the purposes of the Income Tax Act, it is necessary to take into account all relevant facts and circumstances of individual cases.
(31) Pre určenie miesta „bydliska“ daňovníka je relevantné zistiť miesto, kde daňovník skutočne trvale býva, pričomje potrebné prihliadať nielen na možnosť trvalo dostupného bývania daňovníka na určitom území,ale aj na podmienky a skutočné dôvody zdržiavania sa daňovníka na tomto území, okolnosti skončenia predchádzajúceho trvalého pobytu, okolnosti zmeny bydliska, či štátnu príslušnosť daňovníka.
(31) In order to determine the place of "residence" of a taxpayer, it is relevant to determine the place where the taxpayer actually permanently resides, taking into account not only the possibility of permanently available housing for the taxpayer in a certain territory, but also the conditions and real reasons for the taxpayer's stay in this territory, the circumstances of the termination of the previous permanent residence, the circumstances of the change of residence, or the taxpayer's nationality.
31 - the last word translated as nationality, but "štátnu príslušnosť" is citizenship, just for correctness.
Yes, but those are the normal anti abuse rules for people deregistering in their home country. We had long discussions about many different countries. Under no circumstance are they going to tax your Paraguay-born kid that never lived in Bratislava.
As I said before, I was asked vague and general questions. If the country and circumstances are specific, the usefulness and, more importantly, the legality of some solution can be determined.
I remain with my first post in thread. If average digital nomad wish to get the residency in other country - in MY opinion, Paraguay and Georgia are his best shots in terms of costs of setup and maintanence, the simplicity of the process BUT I definetely do not know all solutions, and I am not the smartest and most experienced member of this forum.
Sorry, I don't read Slovak. Even if Slovakia had such a rule (which I doubt, never heard that Slovakia has citizenship-based taxation if you don't take up tax residency elsewhere), it would be a Slovak law, not a general law.
If this was a OECD directive that all OECD countries have to transpose into national law, then it should be easy for you to find the equivalent law in e.g. the UK, so that we can all read it.
Most likely, as @daniels27 also mentioned, you were quoting something from the OECD DTA "master template". But DTAs cannot create new tax obligations, they can only limit existing ones that exist under national law.
Article 4 always starts with a condition that someone is tax resident in both contracting states under their respective national law - and then you can look at things like citizenship. But if you're not tax resident under national law, the treaty cannot create a tax residency based on your citizenship.
And there are lots of countries that won't tax you just for becoming resident. You can take the Baltics as an example, or Cyprus if you stay less than 60 days.
The main advantage with Paraguay is that they'll probably just leave you alone.
But I can't imagine e.g. Cyprus coming after you if you're a pure paper resident and you can prove you spend less than 60 days per year there.
On the other hand, if some other country decides to tax you, your Paraguay paper residency won't be worth much since they have very few tax treaties.
It's not bad, but it's not the great get-out-of-jail-free card some people think it is.
If this was a OECD directive that all OECD countries have to transpose into national law, then it should be easy for you to find the equivalent law in e.g. the UK, so that we can all read it.
Most likely, as @daniels27 also mentioned, you were quoting something from the OECD DTA "master template". But DTAs cannot create new tax obligations, they can only limit existing ones that exist under national law.
Article 4 always starts with a condition that someone is tax resident in both contracting states under their respective national law - and then you can look at things like citizenship. But if you're not tax resident under national law, the treaty cannot create a tax residency based on your citizenship.
And there are lots of countries that won't tax you just for becoming resident. You can take the Baltics as an example, or Cyprus if you stay less than 60 days.
The main advantage with Paraguay is that they'll probably just leave you alone.
But I can't imagine e.g. Cyprus coming after you if you're a pure paper resident and you can prove you spend less than 60 days per year there.
On the other hand, if some other country decides to tax you, your Paraguay paper residency won't be worth much since they have very few tax treaties.
It's not bad, but it's not the great get-out-of-jail-free card some people think it is.
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