Tax Advisory
Private Advisory
Residence position.
Where you are tax resident, established clearly and defensibly.
What it is
Where the line falls.
Tax residence is the first question in any cross-border position, and the one most often left to chance. It turns on a combination of the days you spend and the ties you hold, and the line between resident and non-resident can rest on a small number of either. Where that line falls decides how, and where, your income and gains are taxed.
We review your position against the statutory tests, count and document the days and connections that matter, and make sure the conclusion is one you could stand behind if it were ever questioned. Where a year is finely balanced, we plan around it before it closes rather than after.
How we advise
The statutory tests
Applying the automatic and sufficient-ties tests to your facts, rather than to a rule of thumb.
Day-counting and records
Establishing what counts as a day, and keeping evidence that withstands an enquiry.
Split-year treatment
Identifying where a year of arrival or departure can be split, and on what basis.
Dual residence and treaties
Resolving residence in two countries through the relevant double-tax treaty.
Important information
The basis on which we advise.
This page is general in nature and does not constitute tax, legal or financial advice. Advice is given only under a formal engagement, on the basis of your specific circumstances.
ORA Black advises on the design, selection and coordination of structures; it does not act as trustee, foundation council member or administrator, and does not hold client assets. Fiduciary, formation and administration services are provided by appropriately licensed and regulated providers. Where regulated financial services are required, these are provided through ORA Black’s partnership with NEBA Private Clients.
Discuss your position in confidence.
Speak with a partner