The concepts of domicile and residence are distinct in legal and tax matters. In an international context, it is always fundamental to dissociate the civil analysis from the fiscal analysis of the situation. In an environment in which the increase in taxation in certain countries pushes some people to relocate to other countries, the country of departure in particular will often try to contest the reality of the change of residence from a tax point of view, because the extent of the contribution of the person concerned depends on this qualification. The determination of tax residence is often not as easy as it seems, especially when the taxpayer has homes at his disposal and sources of income in different countries.
Pascal JULIEN SAINT-AMAND, Althémis Paris notaire, answers Jacques DUHEM’s questions.
This study is only available in French.