Or WiseCan happen to anyone, for example from a business competitor, wife etc.
Or WiseCan happen to anyone, for example from a business competitor, wife etc.
What is OECD practice?Having a business in country A is usually a stronger case for centre of vital interest than having a permament address in country B according to OECD practice. That is even more the case if you spend <183 days in country B and if you don't have a rental contract or don't own a home there. There can be an exception in some cases where country A is also the country of your citizenship or you have strong family ties (children, spouse) there. Otherwise, everyone with a holiday home would automatically become a tax resident in every country he possesses a holiday home.
I'm in a somewhat similar situation because I'm owning an apartment, have residence permit, am registered as a sole trader and spend >183 days in Country A (which has favorable tax laws for a part of my business and no CFC rules for natural persons) and would like to have a company with second residency in country B (which has more favorable taxation for another part of my business) but spend only a part of the year there. I know that I could be considered tax resident in B as well but it wouldn't have any negative impact anyway.
If a country grants you an ordinary tax residence certificate (not some "funny business" like the Georgian HNWI certificate) you are tax resident of that country.What is OECD practice?
The term "permanent home available" depends on how each country sees it. Example: Egypt considers the term different from Switzerland.
It doesn't matter if you own, rent or just live there as long as you are in possession of the keys.
However, just building your case on a "permanent home available" is as weak as it can get if you are unable to proof extended presence in the country + local ties.
This would be a question for a specialized tax lawyer who understands the tax law of your country and the country where you want to do your business. IMO just having a parents home in one place doesn't make a case for tax residency without formal proof such as a written rental contract. However, in the case of Boris Becker, having keys of his parents/sister flat together with spending >183 days there was sufficient to condemn him by German authorities.I was wondering if it's enough to have just parents home available without living there.
But I don't only can not prove that I live there, exactly the opposite: I want to prove that I don't.
I want to prove that my residence remains my home country if I am nomad and I want to prove that I don't live there. Which is actually true.I don't understand your second statement. I thought you want to prove that you are tax resident in the country of your parent's home although you have or want to have a business in another country. Now, you're saying that you want to prove that you are not a tax resident in your home/birth country?