Tax residency by country

Unique global-citizenship-based regime: US citizens + green-card holders pay US tax on worldwide income regardless of where they live. SPT brings in non-citizens after 183 days under the weighted formula.

Statutory Residence Test since 2013. 183-day rule is the headline; sub-183-day visits use the Sufficient Ties Test (4 ties: family, accommodation, work, 90-day prior-year). Non-domiciled regime ended April 2025.

ATO applies multi-test framework. 183-day presence is the headline but 'permanent place of abode outside Australia' can override.

Germany applies the Wohnsitz / habitual-abode test. Having a home available + intention to use it > 6 months / year creates residency.

Japan's tax-residency framework distinguishes Permanent Resident (5+ years out of 10) from Non-Permanent Resident (taxed only on Japan-source + remitted income).

UAE introduced a formal tax-residency definition in 2022 alongside the 9% Corporate Tax (in force June 2023). 183-day physical presence + centre of vital interests test.

Singapore IRAS applies 183-day rule per calendar year. Tax residents enjoy progressive rates; non-residents pay flat 24% (or 15% on employment income).

Swiss tax residency triggers earlier than most OECD countries. Lump-sum taxation regime available to qualifying foreign nationals (cantonal variation).

NHR regime offered preferential tax for 10 years (2009-2024). NHR closed to new applicants 2024; replaced by IFICI (Tax Incentives for Scientific Research and Innovation) regime for high-skilled workers.

Thailand expanded foreign-source income taxation in 2024 — Thai-resident high-net-worth individuals taxed on remittance basis under the new framework. LTR visa offers preferential tax in some cases.