The corpus is arranged by jurisdiction: residence thresholds, exit taxes, year splitting, treaties, reporting. Each page answers the question "how is country X built". Someone who is actually leaving asks a different one — "I am walking out of A and into B, what breaks at the join". That answer sits on no single page, because it exists only as the sum of two legal systems: the year rule of the country of departure adds to the year rule of the country of arrival, the price of exit adds to the entry basis, the tail adds to the entry regime.
Writing that sum out pair by pair is not an option. Twelve jurisdictions produce one hundred and thirty-two directed pairs; a text of that shape is dead on publication and will not survive the first tax reform. The matrix is built the other way round: every jurisdiction has two faces — how people leave it and how people enter it — and both are described in a single row. There are not one hundred and thirty-two pairs but twelve rows, out of which the reader assembles the pair.
This page adds precisely the interaction layer and the traps that are visible only at the join. Everything that belongs to a single jurisdiction on its own is handed over by link and not repeated here.
The technique: a row describes a jurisdiction, the reader assembles the pair
The operation is simple, and the whole page exists for its sake. A pair A→B is read in two steps.
- Step one: in the row for country A, take the three left-hand columns — when residence breaks, what the exit costs, what trails behind. That is everything A takes from the departing person and after them.
- Step two: in the row for country B, take the two right-hand columns — how residence arises and which treaty layer applies. That is everything B demands of the arriving person.
- Step three: the two halves are added along six axes and reconciled against one another — not against each country's own calendar separately, but against a single shared timeline of dates.
An example of the assembly. A move from Spain to the UAE: on the left sits the Spanish mechanism — status is assigned for the whole calendar year, there is no splitting, at a census of ten out of fifteen periods article 95 bis LIRPF engages, and Modelo 720 trails behind the years of residence; on the right sits the Emirati one — Cabinet Decision 85/2022 with three tests and an annual residence certificate. The reverse direction, UAE→Spain, is read from the same two rows, but the halves swap places: on the left the Emirati exit, where there is neither tax nor tail, on the right the Spanish entry with its calendar year and its family presumption. The result differs — and that is exactly why direction matters.
Why A→B does not equal B→A
Asymmetry is not a side effect but the architecture of the subject. It arises from at least four independent sources, and each of them works in one direction only.
Gap or overlap: two year rules added together
The United Kingdom knows year splitting: where one of the eight statutory cases is met, the tax year from 6 April to 5 April divides into a UK part and an overseas part, and the splitting date is set by the case itself. Italy knows no splitting at all under domestic law — status is assigned for the whole calendar year, and a partial year is reachable only through a treaty rule laid over a status already assigned. Russia and Spain settle the outcome by the calendar year: Russian status is determined by the number of days in the calendar year, Spanish status by 183 days in the calendar year or by the core of economic interests.
The addition produces a result that appears on neither page separately. A move from a "whole year" country to a "whole year" country — from Spain to Italy, for instance — is capable of producing a year in which both sides treat the person as their resident for all twelve months. A move from a splitting country into a "whole year" country creates no such overlap on the exit side, but does create one on the entry side. And the reverse direction of the same pair may produce neither overlap nor gap — because the order in which the two year rules apply has changed.
The price of exit against the entry basis
The country of departure is entitled to tax unrealised gains at the moment of departure: article 167 bis CGI at a census of six years out of ten and a threshold of EUR 800,000 or a 50% holding, article 95 bis LIRPF at a census of ten periods out of fifteen and thresholds of EUR 4m or EUR 1m where the holding exceeds 25%, the section 877A regime in the United States at net worth of US$2m. The question the country-by-country analyses never ask: does the departing person obtain a new basis on the entry side — a market-value valuation of assets as at the date of arrival.
The answer depends on the country of arrival and has to be checked against it separately: some jurisdictions grant a new basis at the date of entry, others keep the original acquisition cost. The corpus does not yet analyse entry step-up for any of the twelve jurisdictions, so for the country of arrival it has to be verified against primary sources. The UK rebasing rule to 5 April 2017 under Schedule 11 to the Finance Act 2025 is addressed to former users of the remittance basis, not to new arrivals. The practical consequence: where the country of departure has already taken tax on a paper gain and the country of arrival, on the eventual sale, computes the gain from the original acquisition cost, one and the same gain is taxed twice.
Direction decides everything. Spain → United Kingdom: article 95 bis fixes the gain on exit, the UK FIG regime keeps foreign gains outside the charge for the first four years of UK residence, and a sale inside that window produces no double count; a sale in the fifth year runs on the arising basis — from the original base cost, including the slice on which Spanish tax has already been paid. The reverse direction, United Kingdom → Spain, does not create the construction at all: there is no UK tax on unrealised gains on departure.
The tail lives under the law of the country of departure
The third source of asymmetry is the most underrated. Obligations that trail behind a departing person are determined by the law of the country they left, and the regime of the country of arrival has no effect on them. Tails come in three kinds.
- Succession. The UK long-term resident status — residence in 10 of the last 20 tax years — keeps worldwide assets inside the inheritance tax perimeter for a further three to ten years after departure depending on the length of the record, and the "10 out of 20" count itself resets only after ten consecutive years of non-residence. The US section 2801 shifts a 40% charge onto the US recipient of future gifts and bequests from a covered expatriate — with no expiry.
- Reporting. Russian currency residence is tied to citizenship and is never lost: notification of the opening of a foreign account within a month and the annual account-movement report by 1 June remain obligations, and only the exemption in Part 8 of Article 12 of Federal Law No. 173-FZ lifts them — more than 183 days outside Russia in a calendar year. A US green card holder stays inside the worldwide-income system until the status is formally surrendered, not until departure.
- Source. UK land and property stay within UK capital gains tax for a non-resident, with a return and payment within 60 days; French real estate of a non-resident stays within IFI where net value exceeds EUR 1.3m, and SCI shares count towards the base; remuneration of a remote worker of a Russian company remains Russian-source income taxed at 13–22% regardless of tax status.
The country of arrival shortens none of these tails. The zero rate of the UAE and an Emirati residence certificate do not cut the UK inheritance tax tail by a single year; the Italian exemption from inheritance and gift tax on foreign assets during the article 24-bis TUIR regime closes the Italian side, not the British one.
Treaty status as a parameter of the pair
The fourth source is the treaty itself, which has three states: in force, suspended, absent. Without a treaty in force, the ladder in article 4(2) of the OECD Model Convention does not engage, and both states are entitled to treat the person as their resident under domestic law simultaneously.
The Russian case shows that suspension can be partial and asymmetric. Decree No. 585 of 8 August 2023, given statutory footing by Federal Law No. 598-FZ of 19 December 2023, suspended the distributive articles of agreements with 38 jurisdictions; article 4 on residence, the mutual agreement procedure and exchange of information remained in force on the Russian side. But partners responded differently: the United States suspended the same articles in mirror image from 16 August 2024, leaving article 22 on relief untouched; France confirmed the reciprocal step by note of 12 February 2024 with retroactive effect to 8 August 2023; the Czech Republic by note of 13 September 2023. The United Kingdom went furthest and suspended the convention in its entirety, notifying Russia on 4 February 2025: from 1 April 2025 for corporation tax and from 6 April 2025 for income tax and capital gains tax — which means the tie-breaker is switched off for that pair as well.
Treaty status depends on the pair, not on the country. Hong Kong is not on the Decree No. 585 list and the agreement applies unchanged; Singapore is on it (item 36) and its articles 5–22 and 24 are suspended; the UAE is outside the list, and the new agreement of 17 February 2025 applies in full from 1 January 2026 with withholding capped at 10%. Georgia has no treaty with Russia at all. Hence the rule: the treaty layer is checked not by the country row but by the specific direction and on the specific date.
The six axes of the matrix
Both halves of a row are built on the same six axes, and a pair should be reconciled along the same six.
- The moment the old residence breaks and the moment the new one arises: does the year split on the date of the move, or is status assigned for the whole period.
- The price of exit: tax on unrealised gains, the duty to file out the final returns, irreversible loss of a preferential regime.
- The tail: what continues to apply after departure and for how many years.
- Entry: the basis of stay and its connection to tax status — a residence permit does not by itself make a tax resident, and that works in both directions.
- Treaty: in force, suspended, absent; does the tie-breaker engage.
- Visibility: the moment at which both administrations learn about the move.
The matrix: twelve jurisdictions from both sides
| Jurisdiction | How residence breaks on exit | Price of exit | What trails behind | How residence arises on entry | Treaty layer and particulars |
|---|---|---|---|---|---|
| United Kingdom | Year from 6 April to 5 April; the SRT assigns status for the whole year. The breaking date inside the year comes from split-year treatment, Cases 1–3: full-time work abroad, the partner of such a person, ceasing to have a UK home. Case 3 allows no more than 15 days in the country after the home is given up; a former resident is almost always non-resident on fewer than 16 UK days. Notification is by P85 or SA109, but residence is settled by the SRT, not by the form | There is no citizenship-based exit tax and no analogue of Form 8854. Temporary non-residence bites (RFIG21510): residence in 4 of the 7 tax years before departure plus a period of non-residence of 5 years or less means income and gains of the absence period are recharged in the year of return; escaping the rule requires more than five years away. Temporary Repatriation Facility: 12% for 2025/26 and 2026/27, 15% for 2027/28 — leaving the United Kingdom | Long-term resident status (10 of the last 20 tax years) keeps worldwide assets inside inheritance tax for a further 3–10 years by length of record; the count resets after 10 consecutive years of non-residence. UK land and property stay within capital gains tax for a non-resident, with return and payment inside 60 days. A UK pension scheme remains a UK-situs asset, and from 6 April 2027 unused funds fall into the estate — trusts and inheritance tax | SRT: from 183 UK days — resident with no further testing; the automatic tests on sole home and full-time work operate separately; with strong ties residence arrives on as few as 16 days. Split-year Cases 4–8. The FIG regime — 4 years given 10 consecutive prior years of non-residence, claimed on SA109 at the cost of the personal allowance; OWR — the same 4 years, the lower of £300,000 and 30% of employment income. Planning before arrival | The convention with Russia has been suspended by the United Kingdom in its entirety: from 1 April 2025 for corporation tax and from 6 April 2025 for income tax and capital gains tax — for this pair the tie-breaker does not engage. For other pairs, treaty non-residence limits UK taxing rights but does not remove the domestic duty to file (INTM154020) |
| Russia | A mechanical count: 183 days across 12 consecutive months, with the outcome for the tax period settled by the number of days in the calendar year. There is no centre-of-vital-interests test for individuals. The day of arrival and the day of departure both count as days spent in Russia. No application to lose status is filed: the Federal Tax Service determines status itself and retrospectively, as at 31 December | There is no exit tax. The price is the regime: a non-resident pays 30% on Russian-source income with no deductions, and 15% on dividends. The worst case is the sale of Russian real estate by a non-resident inside the minimum holding period: 30% on the whole proceeds with no deduction for costs. CFC duties are closed off by final filings for the year of departure — losing Russian tax residence | Currency residence is tied to citizenship and is never lost: account notification within a month and the annual account-movement report by 1 June; only the rule in Part 8 of Article 12 of Federal Law No. 173-FZ releases them — more than 183 days outside Russia in a calendar year. Remote work for a Russian employer stays Russian income taxed at 13–22% regardless of status — foreign account reporting, dividend tax | 183 days in the calendar year — and days alone. There is no year splitting; status is acquired for the whole period. The basis of stay has no bearing on tax status — relocation from Russia, Russia hub | Decree No. 585 of 08.08.2023 and Law No. 598-FZ: distributive articles with 38 jurisdictions are suspended, while article 4 and exchange of information are preserved on the Russian side. Partner responses vary — from mirror suspension to full suspension. With the UAE, the agreement of 17.02.2025 applies from 01.01.2026 at a 10% withholding cap — treaty suspension, trusts and CFC |
| Spain | Calendar year, with no domestic splitting. A resident is a person who spent more than 183 days in the calendar year in Spain or has the core of economic interests there (art. 9 Ley 35/2006, LIRPF); sporadic absences are not deducted from the count unless tax residence in another country is proved | Art. 95 bis LIRPF: residence in 10 of the last 15 periods, unrealised gains on shareholdings where market value exceeds EUR 4m or exceeds EUR 1m on a holding above 25%. Years under the Beckham regime do not count towards the ten-period census. Leaving the regime: renuncia on Modelo 149 in November–December of the preceding year and irreversible; exclusión on the same form within a month of the breach — leaving the Beckham regime | Duties for the years of residence: the information returns Modelo 720/721 where a category exceeds EUR 50,000, wealth tax on worldwide assets and the solidarity tax on fortunes from EUR 3m (1.7% / 2.1% / 3.5%). Spanish real estate and Spanish-source income remain taxable for a non-resident as well | 183 days in the calendar year or the core of economic interests; a separate presumption arises where a spouse and minor children reside permanently in Spain. The Beckham regime (art. 93 LIRPF): 24% up to EUR 600,000, the year of the move plus five, requiring an employment or entrepreneurial basis and five years without Spanish residence — general regime, Beckham Law, digital nomad. Absent a Schengen stamp, the date of entry is fixed by the declaración de entrada within three days (art. 13 RD 1155/2024) | The agreement with Russia is on the Decree No. 585 list. Savings income runs on the national scale of 19/21/23/27/30%, the top step raised from 28% to 30% from 01.01.2025. The investor residence permit closed on 03.04.2025 (twenty-first final provision of LO 1/2025), but art. 95 bis continues to apply to statuses already granted |
| United States | Residence ends on a legal event, not on departure: formal renunciation of citizenship or termination of lawful permanent resident status. A long-term resident is a green card holder in 8 of the last 15 tax years. Until formal surrender, LPR status keeps pulling the duty to report worldwide income from anywhere on earth | Covered expatriate status under §877A on any one of three tests: net worth of US$2,000,000 or more (§877(a)(2)(B), not indexed); average annual net income tax over five years above US$211,000 for 2026 (US$206,000 for 2025) — §877A(g)(1)(A), section 4.37 of Rev. Proc. 2025-32; inability to certify five years of compliance on Form 8854. Deemed disposal of all worldwide property the day before, with an exclusion of US$910,000 for 2026 (US$890,000 for 2025), §877A(a)(3), section 4.38 of Rev. Proc. 2025-32 — expatriation and exit tax | Citizenship taxes worldwide income indefinitely and irrespective of where life is lived. §2801: gifts and bequests from a covered expatriate to a US recipient are taxed on the recipient at 40% above the annual exclusion of US$19,000 for 2026, on Form 708, with no expiry. Eligible deferred compensation — 30% on payment under W-8CE; distributions from non-grantor trusts — 30% on each payment — U.S. person status | Green card test: an LPR is a tax resident from day one and irrespective of days spent in the country; the substantial presence test operates separately for everyone else. This is the one common route where the immigration card simply is tax residence — U.S. tax residence, EB-5 | The saving clause preserves the US right to tax its citizens and residents as though no treaty existed — a US citizen cannot exit through the tie-breaker. For a green card holder, a treaty non-resident position may be counted as termination of residence with all the consequences of expatriation. The treaty with Russia was suspended in mirror image from 16.08.2024 (Announcement 2024-26), with article 22 on relief untouched. The United States does not participate in CRS, operating through FATCA |
| Italy | Domestic law knows no year splitting: status is assigned for the whole calendar year. A foreign national is removed from the register of the resident population under point b) of paragraph 1 of article 11 of DPR No. 223 of 30.05.1989 — on a declaration of transfer to another commune; the passive route under point c) of the same provision (failure to file a declaration of habitual residence within six months of the residence permit expiring, notice from the commune and 30 days) stretches removal to almost a year. An Italian citizen is removed with simultaneous entry on AIRE (Law No. 470 of 27.10.1988), the application being filed with the consulate within 90 days | The corpus describes no Italian exit tax for individuals. The price is different: early exit from the art. 24-bis TUIR regime is irreversible — re-entry is impossible, and missing the annual payment means losing the regime with no reinstatement. Removal from the anagrafe does not close the question: the Agenzia delle Entrate assesses the factual side — Circular No. 20/E of 04.11.2024, with the composition of the evidence pack tracing back to Circular No. 304/E of 02.12.1997 | The months for which the register entry survived count towards the 183 days and are produced later. Italian income remains subject to ordinary IRPEF of up to 43% plus local surcharges. The exemption from inheritance and gift tax on foreign assets applies only while the regime runs | Art. 2 TUIR as amended by D.Lgs. No. 209 of 27.12.2023, from 01.01.2024: a resident is a person for whom, for more than 183 days of the tax period (184 in a leap year), any one of four conditions is met — civil-law residence, domicile (priority to personal and family ties), physical presence, or registration in the anagrafe as a rebuttable presumption. The art. 24-bis TUIR regime (DPR No. 917 of 22.12.1986; from 01.01.2027, art. 246 of the new Consolidated Income Tax Act, D.Lgs. No. 117 of 19.06.2026, art. 377): EUR 300,000 a year plus EUR 50,000 per family member for a transfer of residence from 01.01.2026 (Law No. 199/2025, art. 1 paras 25–26), EUR 200,000 plus EUR 25,000 for those who transferred from 10.08.2024 (D.L. No. 113/2024), for up to 15 years given 9 of the last 10 years without Italian residence — flat tax, digital nomad visa. For pensioners, art. 24-ter (from 01.01.2027, art. 247): 7% for 10 years in a small southern commune | The treaty tie-breaker engages only after both countries have treated the person as their resident under domestic law, and it is laid over a status already assigned. For Italy this is the only way to obtain a partial year — investor residence and tax residence |
| France | The break is determined by French domestic law and evidenced by the facts of moving the centre of interests; the corpus records no separate year-splitting mechanism | Art. 167 bis CGI: residence for at least six of the last ten years and holdings worth more than EUR 800,000 or a stake of at least 50% in the profits of a company. Unrealised gains are taxed under the PFU at 12.8% plus social levies; on a move within the EU/EEA an automatic sursis de paiement applies, and holding the securities for between two and five years after departure, depending on portfolio size, removes the tax altogether — exit tax | French real estate of a non-resident stays within IFI where net value exceeds EUR 1.3m, and SCI shares count towards the base. Non-resident rental income carries a minimum rate of 20% (30% on the slice above roughly EUR 29,000) plus social levies of 17.2%, or 7.5% for those insured within the EEA. A sale attracts 19% plus 17.2% and a surtax of 2–6% where the gain exceeds EUR 50,000; the holding-period exemption runs to 22 years for the tax and 30 years for the levies. Succession: the réserve héréditaire and the compensatory levy on French assets since 2021 — buying property, intestate succession | Titre talent — a multi-year card bearing the talent endorsement for up to four years (loi n° 2024-42 du 26 janvier 2024; art. L421-21 CESEDA as amended from 28.01.2024), with an investor track from EUR 300,000. The impatrié regime under art. 155 B CGI runs to 31 December of the eighth year following the year of taking up the post, provided there were five calendar years without French tax residence beforehand — the pension layer | The agreement with Russia is on the Decree No. 585 list; France confirmed reciprocal suspension by note of 12.02.2024 with retroactive effect to 08.08.2023. A company in the ownership chain of French real estate pays an annual 3% tax on market value unless it discloses its participants in an annual return |
| Singapore | A foreign national on an Employment Pass, S Pass or Work Permit has no CPF position at all — there is nothing to close. A citizen or permanent resident keeps the balances in the fund, where they continue to earn interest; withdrawal on permanent departure opens up on renunciation of permanent residence or citizenship — CPF. Short-term employment of up to 60 days in a year is exempt (s.13(6) Income Tax Act 1947), but not for directors and public entertainers (s.13(7)); non-resident professionals pay 15% on gross income (s.43(4)) — the 60-day rule | There is no exit tax, no capital gains tax and no inheritance tax | The corpus describes no tail for an individual. The corporate layer stays: a company is resident where control and management are exercised (s.2 ITA), and the owner's move carries that test along — Certificate of Residence | 183 days of physical presence in a year. The 61–182 day band attracts non-resident rules: employment income taxed at the higher of a flat 15% or the resident computation, with no personal reliefs; the resident scale runs to 24% on chargeable income above S$1m (Second Schedule ITA 1947); foreign income of an individual is exempt under s.13(7A). A work pass creates no residence: an EP requires from S$5,600 a month and from S$6,200 in the financial sector (from 01.01.2027 — S$6,000 and S$6,600) and 40 out of 80 COMPASS points — residence, personal income tax, foreign income, GIP | Singapore is on the Decree No. 585 list (item 36): articles 5–22 and 24 of the agreement with Russia are suspended, reduced withholding rates are gone, while the treaty survives as an exchange instrument and as a tie-breaker. Reading it as "Singapore is not on the list" is wrong |
| Cyprus | Exit from the regime runs not on the date of departure but on the census: a resident for 17 of the last 20 years is deemed domiciled, and from year 18 dividends attract SDC at 5% (17% before the 2026 reform) and interest at 17%. Extension is paid for: article 3D of the Special Contribution for the Defence Law — EUR 250,000 per five-year block, a maximum of two consecutive blocks (the 5+5 scheme, up to 27 years), with the procedure explained in Tax Department Circular No. 2/2026 of 29.05.2026; for those who became domiciled in 2024–2026 the transitional filing deadline expired on 30.06.2026 — Cyprus non-dom | The corpus describes no exit tax. The extension payment is non-refundable and made in full and in advance | Capital gains tax remains only on Cypriot real estate. The GeSY contribution of 2.65% applies to dividends, interest and rent with an income ceiling of EUR 180,000 (a maximum of roughly EUR 4,770 a year) | Two tests: more than 183 days in the calendar year, or the 60-day rule — at least 60 days in Cyprus, no more than 183 days in any other single state, business, employment or a directorship in Cyprus, and a permanent home. The condition of "not being a tax resident of another state" was removed from the law by the 2026 reform. Non-dom gives 0% SDC on dividends and interest for 17 years; a foreign pension is taxed at 5% on the amount above EUR 5,000, with the regime elected annually (art. 20 of Law 118(I)/2002) — pensions on relocation, a Cyprus company | An EU member state but not Schengen. The 2026 reform gave priority to treaty rules: a conflict of two residences is settled by the treaty tie-breaker rather than by a domestic condition. Corporation tax rose from 12.5% to 15% |
| Greece | The break is determined by the loss of the grounds of residence; the corpus records no separate year-splitting mechanism. The regime is lost differently — where the fixed tax is not paid in full in any year the relief is annulled, and from that year worldwide income is taxed on ordinary terms with no reinstatement | The corpus describes no exit tax. The price is the irreversible loss of the regime and the fixed sums already paid, which are not refunded | Greek income is taxed on the ordinary progression up to 44% and must be declared in any event — including while the article 5A regime runs | 183 days or the centre of vital interests. Art. 5A of Law 4172/2013 — EUR 100,000 a year on all foreign income, for up to 15 tax years, plus EUR 20,000 per family member; entry requires not having been a Greek resident for 7 of the last 8 years and investing from EUR 500,000 within three years, or holding a valid investor residence permit. Art. 5B — 7% for foreign pensioners, up to 15 years, given 5 of the last 6 years without Greek residence and arrival from a country with an administrative cooperation agreement. Art. 5C — exemption of half of Greek employment or business income for 7 years — Greek non-dom, golden visa, Greece and Cyprus for nomads | The application under 5A and 5B is filed with AADE by 31 March of the tax year concerned, and the deadline is preclusive: a late filing is not considered for that year, the regime starts from the following one and one year of the maximum term is lost. A decision under 5A normally follows within 60 days, additional documents are accepted until the last working day of May, and payment is made within 30 days of assessment. For 5B what matters is precisely a treaty in force with the country of exit |
| United Arab Emirates | The immigration break: an ordinary residence visa is cancelled on continuous absence exceeding 180 days; holders of the ten-year golden visa are exempt from that rule. The tax break runs through the certificate: a TRC is valid for one calendar year, is not issued for a future period and requires a fresh application every year — without 90 days of presence and a connection to the country it will not be issued — UAE tax residence | There is no exit tax, no personal income tax and no CFC rules for individuals | The corpus describes no tail for an individual. The corporate layer remains: an individual carrying on business with turnover above AED 1m in a calendar year must register for corporate tax by 31 March of the following year, on pain of an AED 10,000 penalty | Cabinet Decision No. 85 of 2022, in force from 01.03.2023, art. 4 — three tests: usual or primary place of residence together with the centre of financial and personal interests; 183 days of presence in any consecutive 12 months; 90 days plus UAE or GCC nationality or a valid residence permit, plus a permanent home or work or business in the country. Day counting under MD 27/2023, art. 3: any day or part of a day is a day in the UAE, and the days need not be consecutive — remote work visa, UAE hub | A network of 140+ agreements; the treaty TRC runs under MD 247/2023. The UAE is on neither the Decree No. 585 list nor the list of unfriendly states: the agreement with Russia of 17.02.2025 applies in full from 01.01.2026, with withholding on dividends, interest and royalties capped at 10% |
| Hong Kong | Exit is measured by source rather than residence: salaries tax charges income for services physically rendered in Hong Kong, irrespective of where the employer is incorporated and where the money is paid (s.8(1) and s.8(1A)(a) IRO, DIPN 10). The exemption is narrow — visits of no more than 60 days in a year of assessment (s.8(1B)), with the day of arrival and the day of departure each counted separately, so a trip with an overnight stay consumes at least two days — remote work | There is no exit tax, no capital gains tax, no estate or gift tax, and no withholding on dividends from Hong Kong companies | The corpus describes no personal tail. The corporate tail runs the other way — the risk of migration: a company the owner keeps managing from the new location may become resident in the country of arrival under the management-and-control test (for Singapore, s.2 ITA, corporate tax of 17% under s.43(1)(a)) — a Hong Kong company with a Singapore-resident owner. The seven-year ordinary residence count towards HKPR status is reset by long absences | The IRD criteria for certificate purposes: the individual ordinarily resides in Hong Kong, or is present there for more than 180 days in a year of assessment, or for more than 300 days across two consecutive years of assessment. A Certificate of Resident Status is applied for through eTAX, with processing of around 21 working days. Salaries tax runs on a progression capped by the standard rate: 15% on the first HK$5m of net income and 16% above that from 2024/25 — Hong Kong residence, tax residence and the CoRS, Hong Kong hub | 51 comprehensive agreements in force and a further 8 signed as at 21.07.2026; a CoRS is issued for a specific treaty partner and a specific period. Hong Kong is not on the Decree No. 585 list — the agreement with Russia applies unchanged |
| Switzerland | The lump-sum regime ends not on departure but on an event: taking up gainful activity in Switzerland and acquiring Swiss citizenship. Managing one's own capital does not count as employment; paid roles on Swiss soil are as a rule incompatible with the regime — lump-sum taxation | The corpus describes no Swiss exit tax for individuals. What matters is the countervailing line: Wächtler (C-581/17, 2019) — under the EU–Switzerland Agreement on the Free Movement of Persons, a person moving to Switzerland cannot be subjected to rules harsher than those applying to a move within the EU; that is precisely what forced Germany to replace immediate collection of the Wegzugsteuer with a seven-year instalment plan | The corpus describes no tail. Switzerland has participated in CRS since 2017 (first exchange 2018), and the lump-sum regime does not suspend transparency: a resident's accounts are visible to the former jurisdictions | Entry conditions: not being a Swiss citizen, not working in the country, becoming a Swiss tax resident for the first time or not having been one for the last 10 years. The base is the highest of four figures: actual living expenses, seven times annual rent or the imputed rental value, the indexed federal minimum (CHF 435,000 for 2026, FDF Ordinance of 10.09.2025, AS 2025 579) and the canton's own minimum. Geneva for 2026 — CHF 426,357 for cantonal tax and CHF 468,993 including the 10% uplift on account of wealth tax (art. 14 paras 3 and 4 LIPP). A B permit runs for 5 years, a C permit follows after 10 — Swiss residence permit, a Swiss company | The regime is abolished in five cantons: Zurich (since 2010), Schaffhausen, Basel-Stadt, Basel-Landschaft and Appenzell Ausserrhoden. A resident on the lump-sum regime may be restricted under some double tax agreements — a direct consequence of the special regime, and the treaty position is checked before the move |
Bringing the counters onto one scale
A separate piece of work, without which the pair will not reconcile: two countries count the same twenty-four hours by different rules, and their calendars cannot simply be added together.
- The unit of count. HMRC counts a day by presence at midnight. Russia counts both the day of arrival and the day of departure as days spent in the country. The UAE, under MD 27/2023, counts any day or part of a day. Hong Kong, for the sixty-day exemption, counts the day of arrival and the day of departure each separately.
- The counting window. The United Kingdom and the UAE look at rolling 12 months, Russia and Spain at the calendar year, Italy at 183 days of the tax period (184 in a leap year), and the UK year runs from 6 April to 5 April.
- The consequence. The sum of days across a pair in the year of the move almost never equals 365. A single flight from Moscow to Dubai counts both as a Russian day of departure and as an Emirati day of presence: the same twenty-four hours are recorded by both sides. Conversely, a date fixed by a UK split-year case means nothing to the country of arrival — its own count starts from zero on its own calendar.
That is why the date of the break under the law of A and the date of entry under the law of B are written out in a single chronological sequence, each with the provision applied, and reconciled against that sequence rather than against each national calendar separately. Practical support comes from the quarterly breakdown in platform reporting: both DAC7 and the UK MRDP transmit amounts quarterly, which allows income to be allocated between periods of residence.
Traps at the join
A year of dual residence on a "whole year → whole year" transition
The mechanism. Neither the country of departure nor the country of arrival breaks the year on the date of the move: one assigns status by the outcome of the calendar year, the other for the whole tax period. In the year of the move both treat the person as their resident for all twelve months, and that is not an error but the correct result of applying both laws. Such a year can be cut only by a treaty rule laid over a status already assigned — for Italy that is quite literally the only available way to obtain a partial year.
The direction. Spain → Italy: Spanish status closes on the outcome of the calendar year, Italian status is assigned for the whole calendar year — and they overlap. If the treaty tie-breaker is switched off for the particular pair (as it is between Russia and the United Kingdom from April 2025), there is nothing to cut the overlap with at all, and worldwide income lands in two bases at once.
The gap: "resident nowhere" in the year of the move
This is the commonest form of self-deception, and its technical version is more dangerous than the ideological one. The corpus deals with the perpetual traveler myth as a way of life; the point here is different — the specific window between the loss of the old status and the arrival of the new one.
The mechanism. The date of the break under the law of A and the date on which status arises in B almost never coincide. Spanish status for the year is absent if fewer than 183 days are accumulated in the calendar year and there is no core of economic interests — which is already clear in February. Emirati status requires either 183 days across 12 months, or 90 days together with a valid residence permit and a home or work; the residence permit takes months to arrange. Between those two points lies a window in which neither country treats the person as a resident under domestic law.
What it costs. Without residence there is no certificate, and without a certificate the former country retains grounds for treating the person as its own. Without residence the tie-breaker does not engage: there is nothing to resolve, because formally there is only one claim. The bank reports under CRS regardless — on the data in the file, which is to say the old address or the country of citizenship. Citizenship-based taxation and source rules operate independently of residence altogether. And, decisively, on an audit the country of departure looks at ties, not at the calendar, so a window in which a person is "nowhere" is readily recharacterised as continuous residence in A — with an assessment for the whole year.
The direction. Spain → UAE produces a gap. The reverse direction, UAE → Spain, produces no gap at all: the Spanish count of 183 days runs on the calendar year and, once accumulated by the autumn, covers the months of that year lived in the Emirates as well. One pair, two directions, opposite results.
A gain taxed twice: the price of exit without a new basis
The mechanism. The country of departure taxes unrealised gains at the moment of departure and thereby fixes tax on a paper figure. The country of arrival, on the eventual real sale, computes the gain from the original acquisition cost — if it grants no new basis at the date of entry. Whether it does has to be checked separately for the country of arrival: some jurisdictions do grant an entry step-up and others do not, and the corpus does not yet analyse the question. Where there is no new basis, the difference between the original cost and the value at the date of departure is taxed a second time.
The direction. Spain → United Kingdom: article 95 bis LIRPF takes its share on exit, the FIG regime keeps foreign gains outside the UK charge for the first four years — and a sale inside that window creates no double count. A sale in the fifth year runs on the arising basis from the original cost, and the same slice of gain is taxed again; rebasing to 5 April 2017 does not help here, being addressed to former users of the remittance basis. The reverse direction, United Kingdom → Spain, does not generate the construction: there is no UK tax on unrealised gains on departure. The same arithmetic is worth running for French article 167 bis, where deferral within the EU/EEA is automatic and holding the securities for between two and five years after departure removes the tax entirely — there the price of exit depends on what happens after the move.
The tail the new country does not shorten
The mechanism. The tail lives under the law of the country of departure, and the regime of the country of arrival affects its length in neither direction. The error is one of substitution: a person computes the tax profile of the new country and applies it to their whole position, whereas part of the obligations remain in the old system of coordinates.
The direction. United Kingdom → UAE: the Emirati side is clean — zero income tax, no federal inheritance tax, no CFC rules for individuals. The British side does not change at all: long-term resident status at 10 of the last 20 tax years keeps worldwide assets inside the inheritance tax perimeter for a further three to ten years after departure, a UK pension scheme remains a UK-situs asset, and from 6 April 2027 unused funds fall into the estate. Neither a TRC nor a golden visa shortens that period. The reverse direction, UAE → United Kingdom, produces no tail: on the Emirati side there is nothing to trail.
An entry rule broken by the days of the country of exit
The mechanism. Some entry regimes contain a condition formulated not about the country of entry but about the rest of the world — and that condition is tested against the actual calendar of the year of exit. The Cypriot 60-day rule requires simultaneously at least 60 days in Cyprus and no more than 183 days in any other single state.
The direction. Leaving a country where more than 183 days have already been accumulated by the date of departure closes the Cypriot sixty-day route for the whole transition year: the condition of "no more than 183 days in any other country" is broken by a fact that occurred before the decision to move was taken. What remains is the ordinary 183-day path in Cyprus, and in the year of the move that is usually unreachable. The reverse direction produces no such consequence: leaving Cyprus, a person does not carry its days along as an obstacle. Hence the rule of order: entry conditions are checked against the calendar already lived in the year of exit, not against the plan for the following year.
Visibility: a mismatch of self-certification and double reporting for the transition year
The mechanism. Under CRS a bank determines a client's residence from the self-certification and checks it against indicia — address, telephone, place of birth, standing instructions. Platform reporting is addressed by profile data: the seller's primary address, the state that issued the tax number, the VAT number. None of these channels knows the date of the break — each knows the date on which the data changed.
What it costs. Changing the self-certification before the actual move creates a year in which declared residence diverges from actual residence — a divergence that surfaces at the first reconciliation. Changing it later produces a report for the transition year that goes to the old country, while income for part of that year has already been declared in the new one. Double reporting for the transition year is entirely possible: part of the data goes to the old address, part to the new, and both administrations see the same period from different sides. The order that works: first break the old residence by its own rules and fix the date, then accumulate the basis in the new country, then apply for the regime within the time allowed, and only then change the self-certifications — CRS, tax transparency, platform reporting.
The moment of visibility in the transition year
It is worth recording separately when exactly both administrations learn about the move, because that moment coincides with neither the date of the break nor the date of entry.
The financial channel works on the year-end balance and annual turnover: the bank passes data to its own tax authority once a year, and that authority passes it to colleagues in the owner's country of residence. Residence is taken from the self-certification rather than from the facts, and it changes when the client updates it. The platform channel is built more finely: DAC7 in the EU and the UK MRDP transmit amounts quarterly, and that is the only flow which by itself allows income to be allocated between periods of residence. The addressee is determined by the seller's residence rather than by where the platform is registered — that is, by those same profile fields.
Russia is a special case. Automatic exchange with most Western jurisdictions has effectively stopped: Switzerland dropped off the Federal Tax Service list by Order No. ED-7-17/986@ of 28.10.2022, 26 EU states by Order No. ED-7-17/916@ of 30.10.2024, and the list in force is set by Order No. ED-7-17/883@ of 14.10.2025. Invisibility does not follow from this: the currency resident's duties to notify accounts and to file the annual account-movement report apply whether or not the data arrived, and the RUB 600,000 threshold exemption does not work at all for accounts in excluded jurisdictions.
The limits of the matrix: who is missing
The matrix is honest exactly to the extent that the corpus covers jurisdictions symmetrically, and in two places the coverage is one-sided.
Described on the exit side only are Germany (Wegzugsteuer under §6 AStG: a holding from 1%, a census of seven years out of twelve, instalments over seven years, and from 01.01.2025 fund units as well) and Canada (deemed disposition under section 128.1 ITA). The corpus offers no dedicated entry pages for these jurisdictions — exit tax covers only the left half of the row.
Described on the entry side only are Portugal (IFICI, registered through the Portal das Finanças by 15 January), Turkey (residence permit), Georgia (the territorial system), Kazakhstan (jurisdiction hub), Israel (the 10-year exemption for new immigrants) and Thailand (foreign income tax and the LTR/DTV visas). For those directions only the right half of the pair can be assembled; the left half, for anyone leaving them, has to be built up from primary sources.
The practical consequence is straightforward: a row from the matrix can be taken whole or taken from one side only. A pair in which both halves are supplied by the corpus reads through to the end; a pair with one half missing calls for separate verification, and pretending the gap is not there costs more than admitting it.
Questions and answers
How to assemble a pair that the page does not analyse
Take the row of the country of departure and read the three left-hand columns, then the row of the country of arrival and read the two right-hand ones. Then reconcile them along the six axes: the moment of the break against the moment of arising, the price of exit against the entry basis, the tail against the entry regime, the basis of stay against tax status, the treaty status for that specific pair, and the moment at which the self-certification changes. There is deliberately no pair-by-pair analysis on the page: twelve jurisdictions produce one hundred and thirty-two directed pairs, and a text of that kind cannot be maintained.
Why the reverse direction of the same pair produces a different result
Because the year rules, the price of exit, the tail and the treaty belong to specific countries rather than to the pair, and they swap places when the direction is reversed. Spain → UAE produces a gap in the year of the move; UAE → Spain produces an overlap, because the Spanish count runs on the calendar year and covers the months lived in the Emirates. Spain → United Kingdom can tax one gain twice; United Kingdom → Spain cannot, because no UK tax on unrealised gains on departure exists. Asymmetry here is the norm, not the exception.
What to do if the transition year produces dual residence
Check whether a treaty is in force for that specific pair and on that specific date. With a treaty in force the conflict is resolved by the ladder in article 4(2) of the OECD Model Convention: permanent home, centre of vital interests, habitual abode, nationality, mutual agreement procedure — the detail sits in the tie-breaker analysis. With a suspended or absent treaty there is nothing to resolve the conflict with, and what remains are unilateral foreign tax credit mechanisms, which rarely close it fully. Treaty status does not cancel the domestic obligations of the losing side: reporting, exchange of data and controlled foreign company rules continue to apply under its domestic status.
Is it true that a person can be resident nowhere
Technically such a window in the year of the move does arise — between the loss of the old status and the arrival of the new one — but it is paid for twice over. Without residence there is no certificate, so the country of departure retains grounds for treating the person as its own; without residence the tie-breaker does not engage; the bank reports under CRS on the data in the file, which is to say the old address or the country of citizenship; citizenship-based taxation and source rules operate independently. And on an audit the country of departure assesses ties rather than the calendar: the window is readily recharacterised as continuous residence. As a way of life the construction is analysed in perpetual traveler and five flags.
In what order should the steps of a move be taken
First break the residence of the country of departure by its own rules and fix the date on paper. Then accumulate the basis of residence in the new country — days, home, family, work. Then apply for the preferential regime within the time allowed, remembering that deadlines are preclusive in different ways: in Greece 31 March closes the year for good, in Portugal 15 January shifts the start of the regime to the year of registration, and in Italy the article 24-bis TUIR option is claimed in the return itself. And only then change the tax self-certifications at banks and the profiles on platforms.
Why the price of exit is computed before filing rather than after the move
Because the tax consequences of exit are fixed by events that can no longer be replayed: the date residence is lost, the date the status is surrendered, the valuation of assets at that date. The Spanish window shows it literally: years under the Beckham regime do not count towards the ten-period census in article 95 bis, so someone who leaves immediately at the end of six periods falls outside the exit tax altogether, while every further year on the general regime moves them closer to the census. The American side is built just as strictly: five years of compliance and the valuations are fixed before the consular date, and after the status changes they can no longer be corrected on favourable terms.