Cross-border tax: a checklist before you relocate
The practical items we review with clients before a cross-border move: residency, domicile, entity situs, and reporting obligations.
A cross-border move is one of the few decisions where good planning before the move is materially different from good planning after. This note is the checklist we work through with clients before a relocation.
Residency
Tax residency is determined by the destination jurisdiction, sometimes by treaty. The first question is whether the move creates residency in year one, or only after a statutory day count. The second is whether the source jurisdiction retains a residual claim.
Domicile
Common law jurisdictions distinguish residency from domicile. A change of residency does not change domicile, and domicile can carry a multi-generational tax tail. We document the client’s position before the move and after.
Entity situs
Trusts, holding companies, and insurance wrappers are each taxed according to their situs and the residency of the parties. A structure that works in one jurisdiction may become opaque or penal in another. We review each entity against the destination before the move.
Reporting
Many jurisdictions now require disclosure of foreign assets, foreign trusts, and foreign income. The penalty for non-disclosure is often more severe than the tax itself. We map the reporting obligations and the deadlines before the move, not after.
What we do not do
We are not tax counsel. We coordinate with your tax advisers, document the result, and make sure the wealth plan reflects the post-move position.
For information only. Not tax advice; speak to a qualified adviser about your own circumstances.