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What countries make the most sense Tax Wise for my situaton?

The Malta Global Residence Program (GRP) is available to you. You get a permanent residence in Malta (but you do not need to spend any time there), you get a tax ID (which solves for the issue of the Canadian tax office still coming after you to pay taxes if they discover you have no tax residence), there is no income tax and no capital gains tax payable if you don't repatriate any money. You pay 15,000 Euro a year as "pre paid tax" and you must buy or rent a property. The only restriction is that you cannot spend 183 or more in any other single other country. It's a great option if you have the right income level, I have been in the GRP for about 3 years now and saved a literal fortune on taxes that I would normally pay in Aus.
Hi Cabin14! thanks for sharing your experience! very much appreciated!
I am also considering the TRP/GRP.
Question: Even if not taxed under the remittance basis, Do you need to REPORT your foreign-sourced income? (eg. Stockmarket gains, dividends, salary offshore, etc)
Also, is the Tax Residence Certificate they issue effective for the purpose of treaties?
I would probably need to make use of the TRC in case my country of origin disputes tax residency, so I want to know if in that case I would be able to access the tie-breaker rules under the DTT.
Many thanks in advance!
 
One way is to have multiple home bases on the European mainland, so you dont spend enough time (and avoid to create ties / "centre of vital interest") to be a tax resident in any one European country. You can be a resident in the UAE, have your official address there, and spend some time in Dubai during the winter. Then the rest of the year you can split it between 2-4 countries in Europe. How long you can stay, and what you need to avoid to not get tax residency, depends on each country.

And it is a nice lifestyle regardless of tax benefits.

The most of EU countries has changed a law in a last few years. And CVI is in each country where you own or have rented residential property for 183+ days per year even if you do not spend 183+ days within a country. They call it rule of a toothbush. If you store your toothbrush somewhere permanently and you do not bring it with you, it can be considered a CVI.

So the best way is to travel within civilized world and nowhere own residential property, nowhere have rented residential property long term.
Having rented something on AirBnB for 2-3 months per year and move to another place afterwords is OK.
 
Hi Cabin14! thanks for sharing your experience! very much appreciated!
I am also considering the TRP/GRP.
Question: Even if not taxed under the remittance basis, Do you need to REPORT your foreign-sourced income? (eg. Stockmarket gains, dividends, salary offshore, etc)
Also, is the Tax Residence Certificate they issue effective for the purpose of treaties?
I would probably need to make use of the TRC in case my country of origin disputes tax residency, so I want to know if in that case I would be able to access the tie-breaker rules under the DTT.
Many thanks in advance!
With the GRP you do not declare any of your global income to the Malta tax authorities - only the amounts that are remitted to the country, so basically for us it's the amount for the prepaid minimum tax, the rent, and fees for our agent. We don't bring any other cash into Malta and therefore only pay the minimum tax requirements.

As for the TRC - our agent says they can get one if we need it and it's a legal tax ID from a sovereign country. But as we notified the Australian Tax Office that we were leaving the country and no longer submitting tax returns, we haven't needed it. The key is whether you'll pass the "closer connections" test (or whatever residency tests you have in your home country). We have no property in Australia and we rent a property in Malta - plus we have Malta residence cards, tax IDs etc, so we feel pretty confident with our position.

The added bonus is that with the Malta residency card - we can skirt around the Schengen rules because we don't get stamps in our passports anymore.

It's a good option if you want the flexibility of a pretty good tax residency without a huge capital outlay and no requirement to be in the country.
 
The most of EU countries has changed a law in a last few years. And CVI is in each country where you own or have rented residential property for 183+ days per year even if you do not spend 183+ days within a country.
Got more info on this? Which countries have changed, and how exactly?

Of the countries I follow more closely, i.e. the Nordics, UK/Ireland and Italy, Im only aware of Italy making recent changes to tax residency rules (besides Norway making the exit tax stricter).

Since 2024, Italy has:
#introduced a physical presence test - if you stay at least 183 days in Italy you are a tax resident in Italy.
#made the domicile test focus on familial ties only, and no longer economic interests.
#made it so you are no longer automatically tax resident in Italy if you are registered in Italy, it can now be debated.

So this actually makes it easier to own property in Italy for investment purposes without becoming a tax resident in Italy.
 
Got more info on this? Which countries have changed, and how exactly?

Of the countries I follow more closely, i.e. the Nordics, UK/Ireland and Italy, Im only aware of Italy making recent changes to tax residency rules (besides Norway making the exit tax stricter).

Since 2024, Italy has:
#introduced a physical presence test - if you stay at least 183 days in Italy you are a tax resident in Italy.
#made the domicile test focus on familial ties only, and no longer economic interests.
#made it so you are no longer automatically tax resident in Italy if you are registered in Italy, it can now be debated.

So this actually makes it easier to own property in Italy for investment purposes without becoming a tax resident in Italy.
Netherland, Czech republic, Slovakia, Hungary, Austria, Poland, Greece, Luxembourg. Next will follow soon.
 
Netherland, Czech republic, Slovakia, Hungary, Austria, Poland, Greece, Luxembourg. Next will follow soon.
https://taxsummaries.pwc.com/greece/individual/residence it can be read up here. Greece is not clear and likely wont qualify easily.
countries which profit massively from holiday homes do do this (like italy spain greece).
 
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