What are the factors that affect the tax avoidance effect of international personnel mobility?

People's Mobile Tax Avoidance Planning Law

The content of evading transnational tax payment by the method of personnel mobility is very extensive, which is not limited to the domestic migration of natural persons or legal persons, but also includes the change of the identity of domestic taxpayers. In other words, a person's attempt to change the direction of his resident status and avoid becoming a resident of a country also belongs to the flow of people. If the subjective intention of this flow is tax avoidance, it also belongs to the tax avoidance planning method of personnel flow.

People's mobile tax avoidance planning law is embodied in the residence migration tax avoidance planning law, that is, multinational taxpayers move their residence internationally for the purpose of tax avoidance. Change the identity of residents by moving their residence and avoid exercising the tax jurisdiction of residents in the host country.

The reason why multinational taxpayers want to use the migration of residence to avoid paying taxes is that, in addition to the different tax burden levels in different countries, countries that exercise different tax jurisdictions and residents' tax jurisdictions mostly use the taxpayer's permanent or habitual residence in their own countries as the basis for exercising residents' tax jurisdiction, which is a more direct reason. For example, the residence will be moved from a high-tax country to a low-tax country, and the latter will pay taxes as residents, thus reducing the original tax obligation; Move the domicile from a country exercising tax jurisdiction over residents to a country exercising tax jurisdiction over the source of income, and only pay taxes on the income or property from its source or existing as a resident of the latter in the country exercising tax jurisdiction over the source of income, so as to avoid the tax obligation that should be borne by the country exercising tax jurisdiction over residents; Avoid being a resident by constantly changing the place of residence, and avoid assuming unlimited tax obligations as a resident of any country; By traveling around the world all the year round, staying in any country does not exceed the tax starting point of non-residents and avoids almost all tax obligations.

The tax avoidance planning methods of residence migration can be divided into the tax avoidance planning methods of personal residence migration and the tax avoidance planning methods of corporate residence migration.

Tax avoidance planning law for personal residence relocation

In many countries, people who have a residence and live in the country for a certain period of time or longer are defined as taxpayers. Therefore, it is the key to avoid becoming a resident of a certain country through various means. Because different countries have different standards for resident status, some take the residence period of more than three months, half a year or one year as the standard, and some take the permanent residence as the standard. There are often loopholes between these different standards, which make some multinational taxpayers drift freely between countries and ensure that they will not become residents of any country. At present, some countries restrict it through tax treaties to prevent cross-border tax avoidance. Even so, transnational taxpayers can still evade their tax obligations through some other means and methods. For example, a taxpayer can work for a long time, can engage in activities in different countries and hotels that do not exceed the prescribed time limit, and can also enjoy the tax benefits given by the workplace as a short-term taxpayer. A taxpayer can even live on a boat or yacht to avoid paying taxes to him.

In addition, taxpayers can avoid or reduce their tax obligations by moving their residences. For example, countries living in high-tax areas can try to move to countries with low-tax areas to reduce direct taxes such as income tax, inheritance tax and property tax. This kind of immigration for the purpose of tax avoidance is often considered as "pure" immigration, which is also allowed by countries to avoid heavy tax burden.