Tax Residency Tests by Country
Residency decides which country taxes your income, your gains and eventually your estate. Each interactive test below follows that country’s own statutory rules, shows the reasoning behind the result, and links to the primary sources it is based on.
Why residency is the first question, not the last
Almost every cross-border tax question depends on an answer to this one. Whether your pension is taxable, whether a disposal falls within a capital gains regime, whether your worldwide estate is exposed to inheritance tax — all of it follows from where you are resident, and none of it can be settled without that.
Residency rules are also less intuitive than people expect. They are not reciprocal: two countries can both claim you, and frequently do. They are not uniform: the 183-day figure that appears in most systems is measured over different periods and against different conditions in each. And several of the most consequential tests involve no day count at all, turning instead on where your household is, where your economic interests sit, or simply whether a home is available to you. The tools below work through each country’s statutory test in its proper order and tell you which limb produced the result.
Europe
Day counts, centre-of-interests tests and family presumptions across the major European destinations.
Cyprus
Cyprus offers a 60-day route to residence alongside the standard 183-day rule. The 2026 reform relaxed it further, and made dual residency more likely.
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France
France applies four independent tests under Article 4 B, and the household limb can make you resident even if you spend most of the year working abroad.
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Germany
Germany applies no minimum day count. Keeping a dwelling available for your use, or an unbroken six-month stay, is enough to trigger unlimited tax liability.
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Ireland
Ireland runs two day-count residence tests, but ordinary residence can keep you in the Irish tax net for three years after you leave. Work through both with our tool.
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Italy
Italy’s 2024 reform redefined domicile around family life rather than economic interests, changing the outcome for many internationally mobile people.
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Netherlands
Dutch residence is judged on the circumstances of your life, not on a day count. A home available to you and where your household lives carry more weight than time spent.
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Portugal
Portugal's 183-day test runs on a rolling 12-month window, not the calendar year - a trap that can catch people whose calendar-year day count looks perfectly safe.
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Spain
Spain applies three independent residency tests, and the family presumption catches people whose own day count is well under 183. Work through all three.
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Switzerland
Switzerland's threshold is just 30 days if you work there, or 90 if you do not — the lowest day count in this series, and easy to cross without noticing.
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United Kingdom
The UK Statutory Residence Test decides whether you are taxed on worldwide income or only UK-source income. Work through all three stages with our interactive tool.
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Weighted presence formulas and citizenship-based taxation in the United States.
Canada
Canada asks first whether you kept significant residential ties, not how many days you spent there. The 183-day rule is only a fallback test.
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United States
The Substantial Presence Test weights days across three years, so a repeating travel pattern can make you a US tax resident without any single year nearing 183 days.
Take the testMiddle East
Newer statutory definitions where residency and treaty certification are separate thresholds.
Asia-Pacific
Multi-limb tests combining day counts with domicile and place-of-abode judgements.
Australia
Australia applies four residency tests and only one need be met. The primary "resides" test is a judgement call, not a day count — work through all four.
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India
India produces three possible outcomes, not two. The intermediate RNOR status is where most returning non-residents land, but only for a limited number of years.
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Japan
Japan has three tax categories, not two. The middle one shelters foreign income you do not bring into Japan, and it expires on a date you can calculate.
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Malaysia
Malaysia decides residence mechanically under section 7. Four limbs, any one of which is enough — including one that needs no presence in Malaysia at all.
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New Zealand
New Zealand residence can begin with no day count at all, and it does not end simply because you have left. The permanent place of abode test decides most cases.
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Singapore
Singapore pairs a 183-day count with a qualitative test, then softens both with two administrative concessions. Because resident treatment is usually better, the question is often how to fall inside the test.
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Thailand
Thai residence is a simple 180-day count, but since 2024 foreign income remitted into Thailand is assessable however long after it was earned.
Take the testAfrica
Ordinary residence alongside multi-year physical presence arithmetic.
Tools that go with your residence position
Residence rarely travels alone — domicile, cost of living and capital gains usually move with it.
UK Domicile Test
Domicile is separate from residence and drives UK inheritance tax. Check whether you are UK-domiciled, deemed-domiciled or non-dom under the rules in force from April 2025.
Open RelocationCost of Living Comparison
Compare the real cost of living between where you are now and where you are considering moving, before residence and tax follow you there.
Open Capital gainsCapital Gains Tax Calculator
Estimate the CGT due on a disposal, including how your residence position and temporary non-residence rules affect the charge.
OpenTax residency: common questions
6 questions
What is a tax residency test?
A tax residency test is the set of statutory rules a country uses to decide whether you are taxed there on worldwide income or only on income arising within its borders. Most combine a day count with tests based on where your home, family, work or economic interests are located. The rules differ substantially between countries and are applied independently of one another.
Link to this questionCan I be tax resident in more than one country?
Yes, and it is common. Each country applies its own domestic rules without reference to anyone else’s, so it is entirely possible to satisfy the tests in two places for the same period. Where a double tax treaty exists between them, its tie-breaker provisions decide which country has the primary taxing right, working through permanent home, centre of vital interests, habitual abode and nationality in order.
Link to this questionIs 183 days the rule everywhere?
No. While 183 days appears in many systems, the detail varies enormously. Portugal counts across any rolling 12-month period rather than the tax year. The United States weights days across three years. South Africa requires more than 91 days in each of six consecutive years. Several countries, including Germany and the Netherlands, can treat you as resident with no day threshold at all.
Link to this questionDoes leaving a country end my tax exposure there?
Rarely immediately. Ireland’s ordinary residence keeps most foreign income within charge for three years after residence ends. South Africa requires a continuous absence of 330 days. The UK applies residence-based inheritance tax with a multi-year tail, and temporary non-residence rules can claw back tax if you return within about five years.
Link to this questionDo these tools give me a definitive answer?
No. They apply the main limbs of each country’s statutory test to the answers you provide and show the reasoning behind the result, which is enough to understand your likely position and where the risks lie. They do not capture every exception or anti-avoidance provision, and none of them applies treaty tie-breakers. Treat the output as a starting point for a conversation with a qualified adviser.
Link to this questionHow current are the rules used in these tests?
Each test displays the date its rules were last verified, alongside links to the primary sources — tax authority guidance and the underlying legislation. Where a country has reform proposed but not yet enacted, such as Australia’s statutory residency framework, the tool assesses the law currently in force and flags the proposal separately rather than assuming it will pass.
Link to this questionNot sure where you are tax resident?
Our advisers review cross-border residence positions every day, including cases where two countries both have a claim.
These tools provide general information only and do not constitute financial, legal or tax advice. They assess each country’s domestic rules in isolation and do not apply double tax treaty tie-breakers, which are what decide the outcome where two countries both claim you. Where the answer matters financially, have your position reviewed by a qualified adviser in each jurisdiction involved.