--- name: tax-residency-primer description: "Orient yourself on your tax-residency situation after moving countries — the questions that determine where you owe tax, the double-taxation and dual-residency traps, and what to pin down before you file — so you know what to ask a cross-border tax professional. Use when someone says 'am I tax resident in [country]', 'do I pay tax in two countries', 'moved countries mid-year, what about tax', or 'tax residency rules'. Produces a residency-question map, the trap list, a document checklist, and the questions for a professional. Strictly not tax advice — it orients and routes to a qualified adviser." homepage: https://mohitagw15856.github.io/pm-claude-skills/skill/tax-residency-primer.html metadata: { "openclaw": { "emoji": "🧠" } } --- # Tax Residency Primer Skill Cross-border tax is where confident people make expensive mistakes, because moving countries can leave you tax-resident in two places at once, owing tax you didn't expect, or missing a treaty benefit that would have saved thousands. This skill does exactly one thing well: it *orients* you — the factors that determine residency, the traps to watch, and the specifics to pin down — so that your conversation with a qualified cross-border tax professional is short and productive. It is emphatically **not tax advice**, gives no figures or filings, and its main output is often "here's why you need a professional, and here's exactly what to ask them." ## What This Skill Produces - A **residency-question map**: the factors tax systems actually use (days present, permanent home, centre of vital interests, domicile, the split-year rules) framed as questions to answer for your situation — not conclusions - The **trap list**: dual residency, double taxation, the year-of-move split, exit taxes, reporting of foreign accounts/assets, and remote-work-from-abroad complications — so none ambush you - A **document/fact checklist**: what to gather before filing or before seeing an adviser (travel dates, home ownership/rental, income sources and countries, prior-country status) - The **questions for a professional**: a tight, specific list so a cross-border tax adviser can resolve your situation efficiently — plus how to find one ## Required Inputs Ask for (if not already provided): - The countries involved (moved from → to) and the date of the move - The rough shape of income (employment, self-employment, investments, foreign income, remote work for a foreign employer) — categories only, no amounts needed - Ties to each country (home owned/rented, family, days spent, prior residency) - What's prompting the question (an approaching filing deadline, a job, uncertainty) ## Framework 1. **Frame residency as questions, never a verdict.** Tax residency turns on factors like days present (and the specific counting rules), where your permanent home is, your centre of vital interests, and sometimes domicile — combined differently in every country. The skill lays these out as questions to answer with an adviser; it does not declare you resident anywhere. 2. **Surface the dual-residency and treaty reality.** You can be resident in two countries simultaneously; double-tax treaties then have "tie-breaker" rules and relief mechanisms — but they must be claimed correctly. Flag that this is likely in a move year and that the treaty (if one exists) matters, without interpreting it. 3. **Name the year-of-move and remote-work traps.** The move year is the messiest — split-year treatment, part-year residency, income sourced before/after the move. And working remotely from a new country for an old-country employer creates residency, payroll, and even permanent-establishment questions people rarely anticipate. Flag these prominently. 4. **Build the fact pack.** The adviser will need: precise travel/presence dates, home status in each country, income types and their source countries, prior tax status, and any foreign-account/asset reporting obligations (which carry heavy penalties if missed). Gathering these in advance turns an expensive open-ended consult into a focused one. 5. **Route to a qualified professional — and say why.** Cross-border tax genuinely needs an expert (a cross-border/expat tax adviser or accountant covering both countries). The skill's honest deliverable is a well-prepared client with the right questions, and the clear message that DIY here risks real money and legal trouble. ## Output Format ``` ## Your residency questions (to resolve with an adviser — not answered here) [Days/presence · permanent home · centre of vital interests · domicile · split-year — as questions for your situation] ## Traps to raise [Dual residency & treaty tie-breakers · double-taxation relief · year-of-move split · exit taxes · foreign-account/asset reporting · remote-work-from-abroad] ## Fact pack to gather (before filing / before the adviser) [Travel dates · home status per country · income types & source countries · prior status · reporting obligations] ## Questions for a cross-border tax professional [The tight, specific list · how to find a suitable adviser] ⚠ This is NOT tax advice and contains no figures or filings. Cross-border tax must be handled by a qualified professional for your specific countries and situation. ``` ## Quality Checks - [ ] Residency is framed entirely as questions to resolve with a professional — zero residency verdicts or filing guidance - [ ] The dual-residency/treaty and year-of-move/remote-work traps are surfaced - [ ] A concrete fact pack to gather is provided - [ ] The output routes clearly to a qualified cross-border adviser and says why DIY is risky - [ ] The not-tax-advice line is present and unambiguous ## Anti-Patterns - [ ] Do not give tax advice, figures, filings, or a residency determination — orient only, and route to a professional; this is the hard rule - [ ] Do not interpret a specific treaty or country's rules as settled — flag that they apply and must be handled by an expert - [ ] Do not understate the risk — missed foreign-asset reporting and double taxation carry real penalties - [ ] Do not skip the remote-work-from-abroad trap — it's increasingly common and rarely anticipated - [ ] Do not send the user off without a prepared question list — a focused consult is the whole value ## Related [[arrival-setup]] for the tax-number step; [[credit-from-scratch]] and [[healthcare-system-primer]] for the other newcomer systems; [[micro-retirement-planner]] if the move is a career break; [[financial-model-narrative|budget-variance-analysis]] neighbors for business finances — but a professional owns the tax itself.