@crossborderfl.bsky.socialIf you want the actual text rather than someone's summary.
Article 4(2) of the OECD Model Convention is the residency tie-breaker. The Commentary has the useful detail; the signed treaty for the country pair controls. #TaxResidency #183DayRule #Expat
@crossborderfl.bsky.socialDoes a day count if you left at 6am?
Countries differ on whether days count at arrival/departure or midnight. Reconstructing a year from memory rarely survives a question. #TaxResidency #183DayRule #TaxTreaty #eResidency #Expat
@crossborderfl.bsky.social"Permanent home available to you" doesn't mean owned.
A rented flat you keep, empty, in the country you left — that's a permanent home available to you. It's the first rung of the tie-breaker, and it decides more cases than day counts do. #183DayRule
@crossborderfl.bsky.socialThere are two different 183-day rules and almost everyone merges them.
One is a domestic residency test in some countries. The other is a treaty rule about where employment income is taxed. Different questions, same number, endless confusion. #183DayRule
@crossborderfl.bsky.socialThe 183-day rule is the first rung, not the answer.
If two countries claim you as resident, a five-step treaty ladder breaks the tie. Most mid-year movers are decided at step one or two, before days matter. #TaxResidency #183DayRule
