Where you live, where your company is, where your money sits

Most people trying to work out their cross-border situation are actually asking three different questions at once, and the rules for each are different. Separating them is most of the work.

Where do you live? Where is your company? Where does your money sit?

Each question has its own set of rules, and each answer has its own consequences. tax residency — a status that can determine whether a country taxes or requires you to declare foreign as well as domestic income ¹ — is not the same thing as citizenship, not the same as your immigration status, and not decided by where you earn money ². A company registered in one country is not automatically a company “of” that country for tax purposes ³. And the money that lands in an account is rarely the money that was invoiced, once currency has been involved ⁴.

Where you live

Four things get merged into one in everyday conversation, and they are not the same:

• citizenship — a person’s formal legal membership of a state; nationality is the legal bond between a person and a state, and each state determines under its own law who its nationals are ⁵⁶.
• immigration status — the legal basis, conditions and duration under which a person may enter or remain in a country, which may also affect permission to work ⁷.
• domicile — a legal concept identifying a person’s permanent home, with its exact meaning and tests depending on the jurisdiction ².
• tax residency — the status that determines which country’s tax rules apply to you, established by published tests ².

They are determined under different legal rules, so they need not point to the same country ²⁸.

What tax residency determines is whether a country taxes or requires you to declare foreign as well as domestic income ¹. It is generally determined by published domestic-law tests rather than personal preference ². The Australian Taxation Office, for example, publishes specific residency tests and guidance — the resides test, the domicile test, the 183-day test and the Commonwealth superannuation test — for determining whether someone is an Australian tax resident ². The conclusion follows the applicable legislation and the facts and circumstances — a person’s stated preference is not necessarily decisive ⁹.

Because the tests are rule-based, two countries can both determine that you are resident. Where both countries treat a person as resident under their domestic laws, an applicable tax treaty may contain tie-breaker rules that determine treaty residence ¹⁰¹¹. The sequence runs from permanent home, to centre of vital interests, to habitual abode, to nationality, and finally to mutual agreement ¹⁰. Not every pair of countries has a treaty, and treaty wording can differ from the Model ¹².

Tax Residency Days Tracker — free, no signup, nothing stored.

Next: Tax residency, explained

Where your company is

Where a company is registered is a fact. Where it is treated as tax resident is a conclusion, and the two do not always match ¹³.

Three terms do the work in this area:

• legal seat — the country where the company is formally registered and its registered office sits ¹³.
• place of effective management — the place where a company is actually run and controlled from; for a management-and-control residence test, where its highest-level control is exercised ¹⁴.
• permanent establishment — broadly, a fixed place of business through which an enterprise’s business is wholly or partly carried on ¹⁵.

Corporate residence rules differ by country. Some jurisdictions use incorporation, some use management or control, and some use more than one connecting test ¹³³. Registration in a country may establish residence under that country’s domestic law, but it does not guarantee that another country will disregard where the company is actually managed ¹⁴. A tax treaty may then affect the position if both countries regard the company as resident ³. Registration does not change where you, the individual, are tax resident ².

This is the area where bad internet advice does the most damage. The arrangements described online are often incomplete, out of date, or built on assumptions that do not hold outside their specific jurisdiction.

Next: where your company is treated as resident — a later post in this series.

Where your money sits

For this guide, it is useful to separate four questions: where you are paid, where money is held, in what currency it is held, and what it costs to move it.

The cost of an international payment can include both stated fees and a markup embedded in the exchange rate ⁴. The reference point is the mid-market rate — a midpoint or average between market buying and selling rates, commonly used as a reference rather than necessarily being the rate available for a customer transaction ¹⁶. The difference between a reference rate and the rate offered to the customer is the exchange-rate markup. In wholesale FX terminology, the spread is the difference between the dealer’s bid and ask rates ¹⁷. The markup may exceed the separately stated fee, so both must be compared ⁴.

The invoice can state one currency while the parties arrange payment or conversion in another, subject to the contract and the payment provider’s capabilities and terms. Any conversion carries the markup again ⁴.

FX Reality Check — free, no signup, nothing stored.

Multi-Currency Invoice Generator — free, no signup, nothing stored.

Get-Paid-From-Abroad Decoder — free, no signup, nothing stored.

Next: how money moves across borders — a later post in this series.

How the three interact

The three questions are separate, but their answers interact:

• For a company subject to a management-and-control residence test, where its controlling decisions are actually made can affect its corporate tax residence ¹⁴.
• Where your company is registered does not change where you, the individual, are tax resident ².
• A mid-year move can produce different residence outcomes under the domestic rules of the countries involved: a person may be resident in both under domestic law, and some systems also provide split-year treatment; any applicable treaty must then be checked ¹⁸¹¹.
• Tax residence is determined under the applicable residence rules, not merely by the currency shown on an invoice ².
• Permission to work follows immigration and employment law, while taxation follows tax law; the two questions must be checked separately ¹⁹.

None of these interactions is resolved by paperwork. Each follows the published rules of the jurisdiction in question ⁹.

Start here

The table below routes each common question to the page that answers it.

This site is a set of free, browser-based tools and plain-English explanations for people who earn in one country and live in another. It is not advice, and the person behind it holds no professional credentials. Every fact is sourced and dated 31.8.2026, and open to check. The tools require no account. According to this site’s privacy and methodology statement, calculations run in the browser and the tool inputs are not sent to or retained by the site, except when you explicitly use the optional “email me this scenario” feature ²⁰. Where a question affects money, take it to a qualified accountant.