Summary
Each destination country has its own test for tax residency. Understanding when you become resident abroad is crucial for avoiding dual-residency conflicts and planning your exit from Israel.
USA
- Tests used: The US classifies individuals as resident aliens either by holding a Green Card or by meeting the Substantial Presence Test (SPT).
- SPT formula: Count all days in the current year + one-third of days in the prior year + one-sixth of days in the second prior year. If this total is ≥183 and at least 31 days were spent in the current year, you are typically US tax-resident.
- Scope: US residents are taxed on worldwide income and must file FBAR and FATCA forms for foreign accounts.
Germany
- Primary tests: Tax residency is based on having a permanent home or "habitual abode" in Germany. Presence over 183 days in a calendar year normally leads to residency and worldwide taxation.
- Own exit tax: Germany has its own exit tax (Wegzugsbesteuerung) on substantial shareholdings when leaving Germany, tightened from 2022 onwards.
Canada
- Residential ties: Canada focuses on "significant residential ties": a dwelling, spouse or common-law partner, and dependants in Canada. Secondary ties include memberships, driver's license, and provincial healthcare.
- 183-day deemed residency: Spending more than 183 days in Canada in a calendar year can make you a deemed resident even without many ties.
Portugal
- Tax residency: A person is usually tax-resident if they spend more than 183 days in Portugal during any 12-month period beginning or ending in the relevant tax year, or if they maintain a habitual residence there.
UAE
- Domestic tax residency: An individual is considered a UAE tax resident if they spend 183+ days in the UAE in a 12-month period, or 90+ days with a residence, job, or business there and a UAE center of personal and financial interests, subject to holding a residence visa and Emirates ID.
UK
- Statutory Residence Test (SRT): UK tax residency is determined by three parts: automatic overseas tests, automatic UK tests, and a sufficient-ties test tying day counts to connections such as family, accommodation, and work.
- You are usually automatically resident if you spend 183+ days in the UK or meet home or full-time-work tests.
Action Checklist
- For your chosen country, read the official residency guidance and at least one professional summary.
- Model your day counts and ties over the first few years to see when residency will start.
- Coordinate with Israeli advisors so that the Israeli exit date and foreign entry date are coherent and, where possible, aligned under any treaty tie-breaker.
Important: Local residency rules can be refined by case law and practice. Always confirm current thresholds and exemptions with a local tax professional.