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.