Working remotely
Digital nomad tax guide

Learn how to structure your personal tax affairs as a digital nomad, reduce your global tax burden, navigate residency, and stay compliant across multiple countries. Whether you’re freelancing, remote working, or running your own business abroad, this guide helps you plan your personal taxes efficiently while living and working across borders.

Introduction

If you want to become a digital nomad or if you are working remotely across multiple countries there will be much on your mind. One area that you should consider is your tax position.

As a digital nomad, you may wish to reduce exposure to taxation and at the same time, ensure you remain compliant globally. Generally, it is best practice to organise your tax affairs in good time, to avoid any unnecessary complexities, in the present, future or when you wish to return to your home country.

By seeking answers to the following three questions, this should enable you to understand and organise your global tax affairs while working remotely:

  • Where will I pay tax?
  • How much tax will I pay?
  • What are my tax obligations?

Whether you are a remote employee, business owner, or living off investments, this guide will help you manage and optimise your tax position and ensure you remain compliant with international tax law.

This booklet has been written in general terms and we recommend that you obtain professional advice before acting or refraining from action on any of the contents of this publication. Global Tax Consulting accepts no liability for any loss occasioned to any person acting or refraining from action as a result of any material in this publication.

Domestic resident status

Your domestic resident status is the first and most crucial step in determining where you are liable to pay taxation. This is because your domestic resident status in a country determines the extent to which the country can tax your incomes and gains.

Your resident status is determined by tests created by the national government of the country and you must review your personal circumstances and travel pattern against the tests as this will conclude whether you are resident or non-resident for a particular tax year.  It is a misnomer to rely on the well renowned statement that if you are in a country for more than 6 months, you will be resident and if you are in a country for less than 6 months, you will not be non-resident.

Whilst the majority of countries do assess physical presence when establishing your resident status, there are also a number of other factors that are assessed to determine your resident status detailed to the right. Ideally, your plan should be to manage your travel pattern and personal circumstances so that you establish residency in one country and you do not establish residency in any other country.

The resident country should be a low tax jurisdiction or a tax jurisdiction that offers a special tax regime to expats or digital nomads. Finally, it is strongly recommended that you keep detailed records of physical movements and personal circumstances, as you go, to enable an accurate assessment of your resident status and to provide evidence to the tax authorities to back up the resident status, should this be requested.

What do countries assess?
Physical presence

This is typically assessed by looking at the amount of time spent in a country against a threshold or whether you spent the most amount of time in the country in comparison to other countries globally.

Accommodation

This is typically assessed by looking at the availability of accommodation for your exclusive use over a period of time and the quality of occupation.

Work pattern

This is typically assessed by looking at where you are employed or where your professional activities mostly take place i.e. where you physically exercise work duties.

Centre of vital interests

This is typically assessed by looking at where your social, economic and personal ties are closest to. Factors that may be assessed include the location of your spouse, children, home, assets/investments and employment/business.

High net worth

This is typically assessed by determining whether your net worth on a global level is above a threshold taking into account annual income and value of assets.

Treaty resident status

If you are living and working across multiple countries, you may find that you are domestically resident in more than one country at the same time.  This creates a situation whereby, at a domestic level, you will be liable to pay tax on the same incomes across multiple countries, creating double tax charges.  

To mitigate double taxation, countries have entered into a series of tax treaties or double taxation agreements ('DTA') which seek to reduce your exposure to double taxation, on a global level. The DTAs works by re-assessing your resident status at treaty level using the 'tie breaker' test. In non-tax technical terms, one country will win and one country will lose.

The winner will be able to tax you as a resident at domestic level and the loser will be able to tax you as a non-resident at domestic level.  DTAs can even go as far as removing the non-resident country's taxing rights and thus, the more DTAs a country has, the better, as the DTA's will provide protection against taxation on a global level.

Therefore, you should consider becoming resident in a country that has a lot of DTAs to provide protection from double taxation on a global level, so that you can go about your travels with peace of mind that exposure to taxation outside your resident country will be minimised.

What do countries assess?
Home

This is assessed by looking at the availability of a home for your exclusive use over a period of time and the quality of occupation.

Centre of vital interests

This is assessed by looking at where your social, economic and personal ties are closest to. Factors that may be assessed include the location of your; spouse, children, home, assets/investments and employment/business.

Habitual abode

This is assessed by looking at where you spend the most amount of time on a global level.

Nationality

This is assessed by your nationality.

Residency examples
Mark
Commuter

Mark commutes to Germany during the week and returns to the UK on a weekend. Mark spends 200 days in Germany and 165 days in the UK per fiscal year

Mark has a home in both Germany and the UK, Mark's employment, family and investments are in the UK

Mark is resident in both the UK and Germany under the domestic resident tests. Under the UK/German DTA, Mark is treaty resident in the UK on the basis that his centre of vital interests are closer to the UK.

The UK can tax Mark as a resident and Germany can tax Mark as a non-resident. The UK will tax Mark on his worldwide income and Germany will tax Mark on his workdays exercised in Germany

To minimise double taxation, the UK will give a credit for tax suffered in Germany by way of a deduction against Mark's UK tax bill.

Felicity
Nomad

Felicity is employed in the UAE, maintains a home in the UAE and spends 183 days in the UAE per fiscal year.

For the remaining part of the fiscal year, Felicity travels and works across SE Asia. Felicity spends no more than 30 days in each country and she stays in hostels or air bnbs which are only available for her use whilst she is in the country.

Felicity is resident in the UAE and non-resident in the SE Asia countries. The UAE does not levy personal taxation and thus, Felicity's employment income is not taxed in the UAE. As a starting point, the SE Asia countries will seek to tax Felicity on her workdays exercised in the country.

However, the UAE has DTA's with all the countries that Felicity is working in and on the basis that Felicity meets criteria stipulated by the DTA, the SE Asia countries will not be able to tax her workdays exercised in the countries.

As such, Felicity will not be subject to personal taxation on a global level.

Global non-resident

If you are regularly crossing borders, you may find that you are a global non-resident, meaning that you do not have a tax home. This situation can create tax obligations in multiple countries that you have been working in during the tax year.

With respect to employment income or online business income, over 150 + countries categorise the source of these incomes to be where you physically exercise work duties or where you physically generate trade profits not where your company is located.

As such, if you are global non-resident and in receipt of employment income or online business income, the correct position is to report the portion of income you generate in each country that you worked remotely in during the tax year.

For example, if you work a month in France, you declare a month of salary or business profits in France, if you work two months in Thailand, you declare two months of salary or business profits in Thailand and so on.

Global non-resident example
Sarah

Sarah is a digital nomad who travels perpetually staying in countries for no more than one month per tax year.

Sarah earns £100,000 employment income from a UK employer. The correct position is that Sarah must reclaim tax suffered in the UK and report the portion of employment income relating to workdays physically exercised in all of the countries she worked during the tax year.

US citizen

The US taxation model is citizenship based meaning that you are a US citizen or greencard holder, your worldwide income will be assessable in the US, even if you are an expat living overseas.  

To minimise tax exposure in the US, certain amounts of 'foreign' income can be excluded from US taxation providing that you meet criteria set by the IRS which broadly can be satisfied by minimising physical presence in the US or by acquiring sufficient links/ties to an overseas country.  

In some cases, you may be exposed to double tax charges, on the basis that the country you relocated to will tax your income and the US will tax your income as it is not possible to exclude the particular income from US taxation. If you are subject to double taxation, a foreign tax credit will be available to reduce your tax liability in either the US or the overseas country. The country that is responsible for giving the credit, will depend on international tax law.

US citizen example
George

George is a US citizen and works remotely for a US company.  George returns to the US for a 5 day vacation per calendar year.

George's only source of income is $100,000 of employment income from a US employer. Based on George's limited physical presence in the US, his whole employment income will qualify for an exemption and therefore, George will not suffer US tax on this income.  George will be required to file tax returns in the US to claim the exemption.

Tax systems

Once you have determined your resident status, at domestic and treaty level, the extent to which the resident country can tax your income, depends on the type of tax system the country operates.  The system will dictate whether the country will tax your worldwide income, your local sourced income or even better, the country does not levy personal tax and therefore, the country will not tax your income. Furthermore, many countries offer special tax regimes to foreigners which limits the country's taxing rights.

For example, an individual who is a national of the country may have to pay tax on worldwide income whereas an individual who is a foreigner may have to pay tax on local sourced income only. Therefore, it is possible to turn a less desirable worldwide tax system to a more desirable local sourced tax system, simply by being a digital nomad.  In essence, understanding how tax systems operate, is a fundamental component in enabling you to make informed decisions of where to obtain residency to achieve tax efficiency on a global level.

To put this into practice, on a retrospective basis, you may be living and working in a country that taxes worldwide income and either does not offer a special tax regime or does offer a special tax regime but you have not taken any steps to structure your tax affairs in a manner that enables you to rely and obtain relief through the regime. As such, you should take the relevant steps to ensure that your tax affairs are up to date in the country where you are living and working.  On a prospective basis, understanding how countries will tax your income and furthermore, how to structure your affairs to rely on special tax regimes, is a fundamental step towards enhancing your global tax strategy as a digital nomad.

Taxation models
Zero taxation

Countries that operate a zero taxation system will not tax your income.

Territorial taxation

Countries that operate a territorial taxation system will tax your local sourced income only.

Residence taxation

Countries that operate a residence taxation system will tax your worldwide income.

Citizenship taxation

Countries that operate a citizenship taxation system will tax your worldwide income irrespective of where you are living in the world.

Tax system examples
Zero taxation
Simon

Simon is resident in the UAE and receives 1,000,000 AED salary and 50,000 AED dividends from a UAE company. Simon’s income will not be subject to taxation in the UAE.

Residence taxation
Hilary

Hilary is resident in France and receives £50,000 from a UK pension scheme. Hilary’s UK pension income will be subject to taxation in France

Territorial taxation
Fred

Fred is resident in the Georgia and receives 100,000 GEL online business generated in Georgia and 10,000 GEL dividends from a US company. Fred’s online business income will be subject to taxation in Georgia and Fred’s dividend income will not be subject to taxation in Georgia

Territorial taxation
Lorna

Lorna is resident in the UK and receives £200,000 salary and £10,000 dividends from a UK company. Even though Lorna is resident in the UK, the US will continue to assess her incomes as she is a US citizen

Tax obligations

Once you have determined your resident status and the extent to which countries will tax your income, the final step is reporting your income via an annual tax filing and settling the tax bill with the country's tax authority.  It is important to note that you may have a requirement to make an annual tax filing in a country which you are non-resident. For example, because you receive income in that country, irrespective of whether the income is taxable or not. Every country has a tax year period which, more often than not, follows the calendar year.

Once the tax year period has concluded, you will be required to submit an annual tax filing and settle a balancing payment within a specified timeframe.  For many countries, the filing and payment deadline are aligned and are typically due within 6 months from the end of the tax year period. In addition, some countries may require advance payments of tax to be made within the tax year.

It is also worth noting that rules differ from country to country with respect to calculating your taxable income, particularly in relation to business income. An expense in one country may not be recognised as an expense in another country and therefore, it is wise to reach out to a local accountant to prepare your accounts to ensure compliance with local legislation.  As a disclaimer for global non-residents, it goes without saying that the general consensus is that tax authorities do not have the resources to 'catch' perpetual travellers who hop from country to country.

However, it is without doubt that tax authorities will become more sophisticated and will build systems to track and tax digital nomads. Irrespective of this, hopefully this guide has demonstrated, that with careful tax planning, it is possible to optimise your tax affairs on a global level so that it makes sense to comply with reporting and payment obligations.

What do countries assess?
Annual filing deadline

This is the date that your annual tax return is due. If you file your annual tax return after this date, you run the risk of penalties and interest levied on your tax record.

Annual payment deadline

This is the date that your balancing tax payment is due. If you settle the balance after this date, you run the risk of penalties and interest levied on your tax record.

Advance payments

Countries may require you to make advance payments of tax towards the following tax year. The advance payments will reduce the following years tax bill.

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