Not a resident in any country - What are your experiences? (2024)

Hi Daniela,

Thanks for starting this thread. It’s a really interesting topic that’s relevant for a lot of DNs. Although there’s some good information in this thread already, there are also a lot of inaccuracies. So here’s my attempt at clearing up some of those inaccuracies.

First, this is the best introduction to the whole PT thing I’ve come across (written by “Streber”). Check it out.

As long as you’re no longer tax resident in any country (including country of birth, citizenship, but also others where you’ve lived/worked/have a connection) according to those countries’ domestic rules, it’s totally possible to be a tax resident of nowhere. Note that if you have a US or Eritrean passport (citizenship based taxation) or are born in a country with domicile based taxation (e.g. Australia, Canada, and quite a few more), you’ll probably always be tax resident somewhere (you will always have a domicile, if you lose your previous domicile it reverts to where you were born). But lots (most?) countries don’t determine tax residency based on citizenship or domicile (including most European countries), so it’s not unlikely that you’ll be in the clear.

Always make sure to get confirmations from previous countries where you’ve lived for a significant amount of time (and been registered as tax resident) that they no longer consider you to be tax resident according to their domestic rules.

Being tax resident of nowhere doesn’t necessarily mean that you don’t owe any tax anywhere, however. Generally income (for legal and natural persons) is taxed both based on tax residency and source. If tax residency and source is not the same country, DTAs and unilateral tax credits usually step in to make sure you don’t pay tax on the same income to both. With no tax residency you won’t be able utilize any DTAs, so income is generally taxed at source. This means that you won’t be able to lean on a DTA to reduce the tax burden for income that, for example, is subject to a withholding tax (e.g. 30% for a lot of US source income). But even if your income is not subject to any withholding tax, then the country where you physically perform the work (even just for a day) can tax you on the corresponding income (according to their domestic rules). However, many don’t if you only stay in the country for a short while. And those that have rules in place to tax you from day one, often (usually?) don’t come after you in practice as long as you don’t work for a local employer. It’s definitely a legal gray zone, but the chance of getting in trouble with the tax authorities in a country where you spent 2 month working from your Airbnb is miniscule.

If none of the above caveats apply to you, and you’re okay with being in the above mentioned gray zone, then there’s nothing stopping you from being a true PT.

Still, @ORCA is right that establishing a tax residency can still be beneficial. It makes dealing with banks easier (although you won’t get into trouble for listing your country of citizenship as your tax residency for CRS purposes, as long as you’re not a tax resident in your country of citizenship according to that country’s domestic rules), and will open up opportunities to use their DTAs to lower your tax bill in other countries (where you’re tax liable based on source or withholding taxes). Like @Orca mentioned, Malta is definitely worth a look—especially if you have a EU/EEA/Swiss passport. In that case it’s super easy to register as a “self-sufficient” resident there.

And although the number 183 days is often thrown around as a minimum requirement for being considered a tax resident (through being “ordinarily resident”) in Malta, that’s not really the case. According to Maltese tax law, residing 183 days per year in Malta would make you “ordinarily resident” automatically, but it doesn’t define anyone spending less than 183 days per year as not “ordinarily resident”. If, for example, you spend parts of your winters in Malta, with the intention of doing so year after year in the regular course of your life, then case law suggests that you could be considered “ordinarily resident” and hence also resident for tax purposes in Malta. Plus, it’s in Schengen, so it’s hard to know how long you really spend in the country.

The regular disclaimer applies. Don’t trust what I or anyone else write in some internet forum. Assume we’re all dead wrong and have no idea what we’re talking about. Talk to professionals in those countries that might consider you to be tax resident there to make sure that’s not the case.

Anyway, one classical challenge with a truly location independent life with no home base is whenever you’re asked for a utility bill or similar to prove your residential address (to open various financial or investment accounts, verify Paypal, etc). Often a bank statement will suffice, and many banks will let you change your address on file with them to anything you want, in any country. So just change the address on file for with of your current banks to whatever address you need the confirmation for, and download an online statement. BOOM, that’s sufficient address proof for most situations.

Cheers!