Thanks @xzars for the additional info. I have updated and summarized the idea below:
Tax Residency tiers for HT countries:
Tier 1: The presence test, usually 183 days within a calendar year (or even within any 12 month period)
Tier 2: Tier 1 OR being a citizen/visa holder with social/economic ties to the country
Tier 3: Tier 2 OR being a citizen/visa holder unable to demonstrate tax residence in another country
Tier 4: The scanner is defective and you're always flagged
Examples of countries per tier:
Tier 1: Brazil, Argentina, most non-EU countries
Tier 2: United Kingdom
Tier 3: Denmark, France (*), Greece
Tier 4: United States, Eritrea, Hungary
Examples of (rather subjective and ever expanding) "social/economic" ties criteria for Tier 2:
- Analysis of where is your "center of life" (family, businesses, etc.)
- Analysis of where are most of your assets
- Whether you have "availability of a permanent home" in the country (regardless of living there)
- Analysis of time spent in the country but with more stringent criteria than Tier 1
(*) France and possibly other countries will impose taxation for 3-5 years if your new country of residence is considered a tax haven.
Tier 3 not only for France, Denmark, Greece. It's more like the same with most EU countries. In many countries residency status is explained or based on OECD model.
Here you can check by particular country:
https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/tax-residency/Here is the Residency definition of OECD:
https://www.oecd.org/tax/transfer-pricing/36221030.pdf