The words this site
uses, defined once.
Most of the confusion in this field is two terms that sound alike. A tax exit is something you do; an exit tax is something a country may charge you for doing it. Most members make the first and never face the second. Twenty terms, one meaning each, grouped by where they come up, with the one each is mistaken for.
The move
- tax residency relocation
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Tax residency relocation is the process of legally ending tax residency in one country and establishing documented tax residency in another, including the paperwork both tax authorities require as evidence.
- tax exit
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A tax exit is the departure half of a relocation: ceasing to be tax resident in the country you are leaving, and holding the documentation that proves it if that departure is later examined.
- exit tax
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An exit tax is a charge some countries levy on unrealised gains when a long-term resident ceases to be tax resident, treating assets as sold on the departure date even though no sale occurs.
- tax residency certificate
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A tax residency certificate is a document issued by a tax authority confirming that a person was tax resident in that country for a given period. It is the evidence a former country of residence accepts.
- member
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A member is a client under an active CERØ relocation or annual maintenance engagement.
How countries tax
- territorial taxation
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Territorial taxation is a system in which a country taxes income arising within its own borders and does not tax foreign-source income.
- remittance basis
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The remittance basis is a system in which a country taxes its residents on local income and on foreign-source income only when that income is brought into the country. Thailand applies it: since 2024 a resident's foreign income is taxable in the year it is brought in, whatever year it was earned, unless it was earned before 2024.
- double tax treaty
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A double tax treaty is an agreement between two countries that decides which of them may tax each kind of income, and how the other gives relief, so that the same income is not taxed twice. It applies only to someone who is tax resident in one of the two countries.
- tie-breaker rule
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The tie-breaker rule, article 4 of the OECD model tax treaty, settles residency when two countries both treat someone as resident: it looks in turn at where they have a permanent home, their centre of vital interests, their habitual abode and their nationality.
- centre of vital interests
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The centre of vital interests is the country with which a person's personal and economic relations are closest: family, home, work, business and assets. Tax treaties use it to break ties between two countries of residence, and Spain applies a narrower test of its own, the core of economic interests.
Thailand
- Destination Thailand Visa (DTV)
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The Destination Thailand Visa is a five-year, multiple-entry Thai visa for remote workers, freelancers and people on long cultural stays. Each stay lasts up to 180 days and can be extended once by up to 180 days. It is an immigration status, not a tax status.
- Long-Term Resident (LTR) visa
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The Long-Term Resident visa is a ten-year Thai visa issued through the Board of Investment to four groups — wealthy global citizens, wealthy pensioners, remote professionals and highly skilled professionals — each with its own income or asset thresholds. Like the DTV, it grants residence, not a tax status.
- Thai 180-day rule
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The Thai 180-day rule, in section 41 of the Revenue Code, makes anyone physically present in Thailand for 180 days or more in a calendar year a Thai tax resident for that year. It is a day count only: there is no ties test and no centre-of-interests test.
Paraguay
- cédula (Paraguay)
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The cédula is the Paraguayan identity card a foreign resident receives once residency is granted, and the document that proves it. Paraguayan tax residency is a separate status, shown by a certificate from the tax authority.
Leaving Europe
- Modelo 030
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Modelo 030 is the Spanish tax agency's form for changes to a taxpayer's census data, including an address abroad. Filing it tells the AEAT where you now live; it does not by itself end Spanish tax residency, which turns on the tests in article 9 of the IRPF Law.
- article 95 bis
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Article 95 bis of the Spanish IRPF Law is Spain's exit tax: on leaving, someone who has been Spanish tax resident for at least 10 of the last 15 years is taxed on the unrealised gains in their shares if these are worth more than €4 million, or more than €1 million where the holding exceeds 25% of a company.
- Wegzugsteuer
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The Wegzugsteuer, in §6 of Germany's Foreign Tax Act (AStG), is Germany's exit tax: it taxes as if sold the shares of anyone who held 1% or more of a company in the previous five years and has been German tax resident for 7 of the last 12 years. Since 2025 it reaches large fund holdings too.
- conserverende aanslag
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The conserverende aanslag is the Dutch protective assessment, under article 4.16 of the Income Tax Act 2001, raised on emigration over the unrealised gain in a substantial shareholding (5% or more). It is collected when the shares are sold or dividends are paid, and for anyone who left after 15 September 2015 it never lapses.
- Statutory Residence Test (SRT)
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The Statutory Residence Test is the UK's rule for tax residency, in Schedule 45 of the Finance Act 2013. It combines day counts with ties to the UK, and each tax year, from 6 April to 5 April, is judged on its own.
- split-year treatment
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Split-year treatment divides the UK tax year in which someone leaves into a UK part and an overseas part, so that income after the departure date is taxed as a non-resident's. It applies only in the cases the Statutory Residence Test lists, not to every departure.
The same definitions, for machines
These are the definitions CERØ publishes for AI assistants and search engines, word for word. They are served as plain text as well, so a model can read them without parsing this page.
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