10M.+ optimization tax residency when you have 3/4 bases.

[JohnnyDoe]

In LATAM yes... but in Asia?

Danger comes from people. Or are you afraid of monkeys stealing your sunglasses?

If all you want is a piece of paper stating that you reside somewhere, you have plenty of options, but eventually this game will get you into trouble.

 

[toums]

Danger comes from people. Or are you afraid of monkeys stealing your sunglasses?

If all you want is a piece of paper stating that you reside somewhere, you have plenty of options, but eventually this game will get you into trouble.

It's not about playing. I suppose I was quite well organized/structured and full white until now.

To resume (again) quickly, all I want/would do is :
- Not living anywhere 6 months.
- No business or physical activity anywhere.
- 100% of passive income (dividends, interets, some real estate income i pay tax in the country where real estate are located) AND crypto capital gain (+ stock capital gain).
- No time (1month a year) in my citizenship country BUT 5/6 months in total in Europe in 2 different base (Budapest + something next to the sea/ocean);
- Rest of the time I consider more Bangkok as a 'base' because I like BKK and easy to travel anywhere around.
- I can consider Dubai as tax residency if I can skip legally the 90days minimum as it's exactly between EU and SEA.

 

[Mercury]

Well, if Thailand my plan is not to stay the whole year, maybe 5/6months a year. I don't plan to make business there or remitted my money. I can keep my money easily outside Thailand. Probably I would rent or buy a nice condo in BKK, but if I understood well, not need to pay any tax on it if I can prove that this money was earn before 2024, correct?

Implicating a wedding with a thai and all these grey/borders things with no plans to rapatriate the money in the Kingdom seem to be more stressfull, incertain and useless, no?

All offshore income earned prior 1 Jan 2024 and remitted in Thailand is indeed tax-free.

If you plan to reside less than 6 months a year in TH then you can certainly sort out your stay via 30 days visa exemptions and tourist visas.

- I can consider Dubai as tax residency if I can skip legally the 90days minimum as it's exactly between EU and SEA.

Why do you need a tax residence?

France certainly does not ask for tax certificate and you can't be considered FR tax resident as long as you don't meet one of these 3 criteria:
- You have your household there or, if you do not have a household, it is the location of your main abode.
- You have a professional activity in France, as an employee of otherwise, unless this activity is secondary.
- The centre of your economic interests is in France.

https://www.impots.gouv.fr/residents-france

 

[JohnnyDoe]

It's not about playing. I suppose I was quite well organized/structured and full white until now.

To resume (again) quickly, all I want/would do is :
- Not living anywhere 6 months.
- No business or physical activity anywhere.
- 100% of passive income (dividends, interets, some real estate income i pay tax in the country where real estate are located) AND crypto capital gain (+ stock capital gain).
- No time (1month a year) in my citizenship country BUT 5/6 months in total in Europe in 2 different base (Budapest + something next to the sea/ocean);
- Rest of the time I consider more Bangkok as a 'base' because I like BKK and easy to travel anywhere around.
- I can consider Dubai as tax residency if I can skip legally the 90days minimum as it's exactly between EU and SEA.

With such setup eventually someone will want your money, most probably France. The world is changing.
If you like Thailand, setup a proper base there (not a rented condo) and spend more than 6 months per year. Possibly also have a local wife/husband, buy a car, get a membership at the local golf club etc. You could also consider buying a small local business like a bar or a gym.

 

[pomegranate]

.. have a local wife/husband ...

in Thailand you can get two in one.

More seriously, these setups will work for a while until they catch you. If you are not really a tax resident in any country, I wouldn't be surprised if they revert to the concept of domicile vs tax residence for reporting, etc. And the first one to go after you will be your country of citizenship (France in your case). It doesn't mean they will win their case but you will have to spend time/money to argue against it.

 

[toums]

With such setup eventually someone will want your money, most probably France. The world is changing.
If you like Thailand, setup a proper base there (not a rented condo) and spend more than 6 months per year. Possibly also have a local wife/husband, buy a car, get a membership at the local golf club etc. You could also consider buying a small local business like a bar or a gym.

Can you tell me, from your opinion, how they can challenge me (and win) if I can easily proove i spend only 1 month a year there since decades. No wife No kids there. No business in france, no activity in france, no economic center interest in France. No money transiting in France. Do you think they have reasonably more than 1% to win ?

If tomorrow (in decades, or more), France pass to the extreme left political (kind of stupid Jean Luc Mélenchon), and want to try to impose you regarding your citizenship (like in US). But this scenario I put chance maybe 0.5% to 2 % (have to be elected AND able to change the constitution) and in that case you can still adapt and buy other passports if the situation getting very tricky..

in Thailand you can get two in one.

More seriously, these setups will work for a while until they catch you. If you are not really a tax resident in any country, I wouldn't be surprised if they revert to the concept of domicile vs tax residence for reporting, etc. And the first one to go after you will be your country of citizenship (France in your case). It doesn't mean they will win their case but you will have to spend time/money to argue against it.

That's why I want to keep a official tax residency somewhere. Until now it's 100% clear with Portugal, i am tax resident under NHR scheme. Before i was under non dom in Malta.

That's why also I was considering :
a) Dubai (even if not my first choice and spending there 90days IF REALLY necessary).
b) Thailand, as I heard you dont have the obligation to spend a minimum of 180days there (you become automatically tax resident from 180days a year) BUT you can ask for your tax number with less minimum presence and declare little bit of money there to pay some tax.
c) If a) + b) are not working/suitable, still have the possibility to keep NHR in Portugal without spending 6 months there (it's also clear in Portuguese tax authority you dont need 6 months presence there) and you have all DTAs in case of challenging (by France?!) OR taking my second base in Europe back in Malta, and take again the non-dom as tax residency without spending 6 months and pay the 5000€ tax per year, and get also the tax certificate.

I think in my case/wishes it's complicated to reach the 100,00% safe, but probably it's possible to find legal solution to be near this number WITHOUT have the obligation to spend Minimum 6 months anywhere. And I insist on that point, I don't plan to have any business / local activity in ANY of these countries, except my investments and passive income.

 

[JohnnyDoe]

Can you tell me, from your opinion, how they can challenge me (and win) if I can easily proove i spend only 1 month a year there since decades. No wife No kids there. No business in france, no activity in france, no economic center interest in France. No money transiting in France. Do you think they have reasonably more than 1% to win ?

they are the mafia, they always win. It’s them who create, interpret and apply the law. It doesn’t matter if you are “right”, because having money makes you automatically wrong. You might be lucky and find a good judge, but they can still imprison you, confiscate your assets, torture you and your family for years. Until you eventually give up, or end up broke, or dead. Meanwhile you will have paid millions in legal fees and wasted your best years.
Open your eyes, please.

 

[jafo]

That's why I want to keep a official tax residency somewhere. Until now it's 100% clear with Portugal, i am tax resident under NHR scheme.

You've been in Portugal for a long time, so here:

Note: My agnate grandfather is Portuguese. My family is from all over Europe. They were all European immigrants looking for a better life post-WWI and then post-WWII before the "EU community" or Euro was created.

Take the wisdom of @banafinfodafuggiano's writings...

I have the same question as you except I'm worth 1/10 of your declared net worth and I have a family with kids.
Even my wife of 10 years doesn't know how much money I earn or I have in the bank.

If I was you I would keep my mouth shut to anyone including your family, friends and future girlfriend about your net worth.
Plenty of bad stories in Thailand of guys getting kidnapped and their crypto stolen at gun point.

Go wherever you think is best, just keep your mouth shut down all the times.

I have several relatives in Europe. Some are migrant workers, and others are just backpackers. They are financially poor! They use every govt. trick to get free stuff. There isn't a single tax agency that is interested in them. They want them to disappear. They haven't paid proper taxes in over 50 years—some even more. The tax agencies can't squeeze blood out of a rock!

On the other hand, many of my "clients" who pay exorbitant amounts of taxes in Europe (country-independent) and are worth millions, tens of millions, some even hundreds of millions of euros, have been in constant legal battles with tax agencies as far back as I can remember. - I won't go into this issue any more. It's depressing and counterproductive.

What @JohnnyDoe was trying to imply and shed light on is that it is impossible for Europe to sustain its expenses economically with the current influx of non-working people. Somebody has to pay for it and the "political sewer" has NEVER EVER produced ANYTHING of value. Just keep this in mind. Personally, I choose countries that are NOT immigrant-friendly! Just like I choose "business clients & suppliers" who are not TAXING on me or my structure (pun deliberately intended ).

Your setup is working fine. Govern yourself accordingly! Nobody here knows your setup and its intricacies better than you!
*NOBODY*!

If you want to upgrade, identify what you need to upgrade beforehand.
Create, e.g., a spreadsheet where you can juxtapose today vs. a more profitable future.
Travel! Go on a reconnaissance mission/vacation. Verify & confirm. Trust NO ONE!

Gather the information you seek WITHOUT disclosing your purpose!

@wellington is indeed someone who knows Thailand very well. There are a few others here, too. They have either lived there or are living there.
I've been to Thailand many times as a tourist, but my knowledge of Thailand is so bad that I dare NOT utter it, as I may only get people in trouble. I know jack sh1t about Thailand, and I'm NOT afraid or embarrassed to admit this. Look for someone who has successfully lived there or is successfully currently living there and has NO interest in you or your "loot."

Do NOT enter into ANY agreements or schemes where someone else can blackmail you! No "arranged wife" BS! I've seen a myriad of these end up with the "husband" behind bars until they paid a fine to the government and the wife's family. Do NOT do anything with ANYONE else who can testify against you that is illegal or even in the gray zone! Nothing! That's NO way to live!

There are plenty of things I do that are in the gray zone, but ONLY I know about them.
Two people can keep a secret...if one of them is DEAD!

I'm not sure how good your Spanish is, although knowing Portuguese will help you navigate my adage:
Paso corto, vista larga, mucha mala leche, y MUCHA, pero MUCHA mala fe!

Success!

 

[void]

Singapore, Hong Kong, Auckland, Sydney, Melbourne, Rome

safety has many flavors and (like everything else) has subjective scale - how did you enjoy these places during covid? was it "safe" enough?

 

[Mercury]

Can you tell me, from your opinion, how they can challenge me (and win) if I can easily proove i spend only 1 month a year there since decades. No wife No kids there. No business in france, no activity in france, no economic center interest in France. No money transiting in France. Do you think they have reasonably more than 1% to win ?

With its current tax residence rules France can't challenge you as long as:
- You don't meet the tax residence criteria and you can justify a residence address abroad for each year being non-resident in France.
- You have declared your address change to the French tax authority.
- You have performed a consular registration in the register of French nationals established outside France.
https://www.service-public.fr/particuliers/vosdroits/F33307?lang=en
Now, if someday France moves to citizenship-based taxation (I doubt) it won't be retroactive and you'll be anyway bulletproofed if you have respected the conditions listed above. Then, you could structure yourself accordingly.

Don't fall for the FUD, enjoy your life out of EU keeping low profile whether in Thailand, SEA or any other corrupted and mismanaged country and everything will be fine.

 

[JohnnyDoe]

With its current tax residence rules France can't

Don’t ever think that a country, especially a western corrupt and declining one, can or can’t do something.

challenge you as long as:
- You don't meet the tax residence criteria and you can justify a residence address abroad for each year being non-resident in France.

That’s the point. It has to be a real residence, they makes sense in the eyes of a prosecutor and a judge. Try to convince them that a $10m+ worth guy really lives in a rented condo and that’s all the ties he has with that country.

 

[Cloudbanck]

Don’t ever think that a country, especially a western corrupt and declining one, can or can’t do something.

That’s the point. It has to be a real residence, they makes sense in the eyes of a prosecutor and a judge. Try to convince them that a $10m+ worth guy really lives in a rented condo and that’s all the ties he has with that country.

It also that France (along with Italy, Spain, Australia and of course the US) is one of the aggressive countries that keeps track of its citizens living abroad, especially if they are wealthy. In such cases France might come up with some reason/interpretation that a wealthy citizen is a tax resident in France after all.

Most high tax countries are not like this, once you move out properly they usually stop tracking you, and you dont have to show where you live every year. The trend isnt great though, it's somehwhat leaning towards aggressiveness.

Anyway, best is to move out of a high tax country when one is young, before one has made significant money and gotten a house and family and a dog. And if one is a citizen of an aggressive high tax country, consider getting another citizenship.

 

[Armani]

Perfect combo in EU to me is Hungary and non dom res in Cyprus.

I also was a NHR in Portugal, it is good because nobody checks anything but i have found that women are not interested in me and cost of living in Lisbon today doesn't make sense.
So now i only go for holidays there like in Spain, Thai or Brasil.

 

[MarkusCostigan]

Can you tell me, from your opinion, how they can challenge me (and win) if I can easily proove i spend only 1 month a year there since decades. No wife No kids there. No business in france, no activity in france, no economic center interest in France. No money transiting in France. Do you think they have reasonably more than 1% to win ?

If tomorrow (in decades, or more), France pass to the extreme left political (kind of stupid Jean Luc Mélenchon), and want to try to impose you regarding your citizenship (like in US). But this scenario I put chance maybe 0.5% to 2 % (have to be elected AND able to change the constitution) and in that case you can still adapt and buy other passports if the situation getting very tricky..


That's why I want to keep a official tax residency somewhere. Until now it's 100% clear with Portugal, i am tax resident under NHR scheme. Before i was under non dom in Malta.

That's why also I was considering :
a) Dubai (even if not my first choice and spending there 90days IF REALLY necessary).
b) Thailand, as I heard you dont have the obligation to spend a minimum of 180days there (you become automatically tax resident from 180days a year) BUT you can ask for your tax number with less minimum presence and declare little bit of money there to pay some tax.
c) If a) + b) are not working/suitable, still have the possibility to keep NHR in Portugal without spending 6 months there (it's also clear in Portuguese tax authority you dont need 6 months presence there) and you have all DTAs in case of challenging (by France?!) OR taking my second base in Europe back in Malta, and take again the non-dom as tax residency without spending 6 months and pay the 5000€ tax per year, and get also the tax certificate.

I think in my case/wishes it's complicated to reach the 100,00% safe, but probably it's possible to find legal solution to be near this number WITHOUT have the obligation to spend Minimum 6 months anywhere. And I insist on that point, I don't plan to have any business / local activity in ANY of these countries, except my investments and passive income.

Why did you move from Malta to Portugal ?

 

[JohnnyDoe]

i have found that women are not interested in me

probably the reason is not the NHR status

 

[jafo]

probably the reason is not the NHR status

You couldn't resist, could you?

 

[CyprusLawyer101]

In Cyprus you will get 0% on passive income such as dividends and interest. Also easy to establish your tax residenxy and most people here dont really want to grab your money.

 

[toums]

they are the mafia, they always win. It’s them who create, interpret and apply the law. It doesn’t matter if you are “right”, because having money makes you automatically wrong. You might be lucky and find a good judge, but they can still imprison you, confiscate your assets, torture you and your family for years. Until you eventually give up, or end up broke, or dead. Meanwhile you will have paid millions in legal fees and wasted your best years.
Open your eyes, please.

Well JD.. I am really not active on this forum but as I saw you seem smart and very respected here for global optimisation. Maybe you're right but you seem OVER Bear (pessimist), and in that case France or another country can also challenge you if you live in any banana (caribbean) republic for 6months more, just by argue 'you want to skip tax' and/or 'you are citizen of my country so i will tax you'. With these EXTREME examples, everything can happen to anyone.

With its current tax residence rules France can't challenge you as long as:
- You don't meet the tax residence criteria and you can justify a residence address abroad for each year being non-resident in France.
- You have declared your address change to the French tax authority.
- You have performed a consular registration in the register of French nationals established outside France.
https://www.service-public.fr/particuliers/vosdroits/F33307?lang=en
Now, if someday France moves to citizenship-based taxation (I doubt) it won't be retroactive and you'll be anyway bulletproofed if you have respected the conditions listed above. Then, you could structure yourself accordingly.

Don't fall for the FUD, enjoy your life out of EU keeping low profile whether in Thailand, SEA or any other corrupted and mismanaged country and everything will be fine.

It's what I did since 2013. 0 tie there. Address changed from 2013 to Hungary (at this time) and i am registered ofc at the consulate (hungary, then malta, then Portugal).

That’s the point. It has to be a real residence, they makes sense in the eyes of a prosecutor and a judge. Try to convince them that a $10m+ worth guy really lives in a rented condo and that’s all the ties he has with that country.

Not agree again with that. What the point with rent or buy? I can rent a 300 sqm penthouse at 5K$+ a month in BKK or buy a T1 40sqm for 150K$.. What is the more relevant for tax residency?

Perfect combo in EU to me is Hungary and non dom res in Cyprus.

I also was a NHR in Portugal, it is good because nobody checks anything but i have found that women are not interested in me and cost of living in Lisbon today doesn't make sense.
So now i only go for holidays there like in Spain, Thai or Brasil.

Can you explain why HU + non dom Cyprus? Before Portugal, I had non dom Malta + second base in Hungary.

For Portugal, I am agree Portuguese women really not interesting BUT lot of Brasileira and Africans (cabo verde, mozambica and Angola), if you like "Chocolat".

Why did you move from Malta to Portugal ?

Malta is not bad BUT really too small and wasn't clear for crypto taxation. I found similar way with NHR (except for capital gain in 'traditionnal' markets, but not a big deal for now for me) but more clear with crypto, and BIGGER country / diversity.

 

[jafo]

Brasileira

This guy is definitely in Portugal!

 

[toums]

This guy is definitely in Portugal!

It's resuming my portuguese language skills : grande bunda / bundinha / bola rebola / peitos grande