CITIZENSHIP
| Time | What is the minimum time of residence required to apply for citizenship? |
| Ease | Is it easy to become a citizen or restrictive? Does the country traditionally welcome new citizens (e.g. Canada) or is it restrictive (e.g. UAE)? |
| Language | Are there strict language requirements? |
| Other restrictions | Are there other restrictions on becoming a citizen (e.g. sub-national restrictions, cultural, ethnic, etc.)? |
| Visa-free travel | Do citizens enjoy good visa-free travel? |
| Cost | What is the cost to obtain and maintain citizenship? |
| Obligations | Does citizenship come with burdensome obligations (e.g. military service, taxation)? |
| Status | Does citizenship provide national or international social status benefits? |
| Revocation | Under what circumstances can citizenship be revoked? |
LEGAL AND TAX
| Taxation | What is the taxable base and rate of taxation of the following? • Income and capital gains taxes • Net wealth and property taxes • Inheritance and gift taxes Are there good tax planning options? |
| Matrimonial and divorce law | Will pre-nuptial agreements be recognized in this country? What impact does residence in the country have on a possible divorce filing? |
| Real estate market | What is the state of the real estate markets (residential, commercial)?What is the availability of residential real estate for rent and purchase? |
| Real estate acquisition | Is it easy to acquire property? What are the transfer duties payable? Are there any restrictions on buying or selling? |
| Estate planning | Are there forced heirship rules?Can you use trusts or foundations?Do you need to adjust your will and other instruments of succession planning? |
| Licensing, business permits | How easy is it to set up a business? Are there license and permit rules that one must abide by, i.e. license for carrying out a profession, driver’s license, boat license etc? |
| Law enforcement and courts | How effective is the local law enforcement?Is there a reliable legal system?Can claims be effectively pursued in court? |
1.5 Tax residence: considerations and implications
To determine if a person should be subject to taxation, countries generally use the following criteria:
• Residence: a country may tax the income of anyone who lives there, regardless of citizenship or whether the income was earned in that country or abroad
• Source: a country may tax any income generated there, regardless of whether the earner is a citizen, resident, or non-resident
• Citizenship: a country may tax the worldwide income of their citizens, regardless of whether they reside in that country or not
For the internationally mobile, the tax position across different countries will be an important concern. But the amount of tax they pay is also of interest to the relevant tax authorities. The simple rule is, the more you pay, the more interesting it becomes - for both sides.
Most countries use residence and/or source when determining if a person should be subject to taxation. The US, and to a lesser extent some other countries,6 are notable exceptions.
The place of residence for tax purposes or tax residence is therefore important in determining how you are taxed. If you have connections with, and spend long periods in, more than one country, there may be uncertainty about whether such connection or time spent in different jurisdictions does not make you tax resident in more than one place. The question of tax residence is very important for internationally active people, because getting it wrong can be expensive and time-consuming to resolve.
Other than the number of days spent in a country - which is perhaps the most important factor – a wide range of personal, business, property, economic and social connections must also be considered to determine “tax residence”.
In many countries, the laws and regulations are ambiguous, except for minimum thresholds (i.e. below a certain number of days of presence in the country - with anywhere between 10 and 90 days a year, you are generally safe and would normally not be deemed resident for tax purposes, depending on the country), and there is generally no clear guidance on the relevant weight of each factor.
Factors that can play a role include
• Where your spouse
