Technical article

What Counts as Becoming a Tax Resident, Country by Country

Spain counts more than 183 days in a calendar year.

By Neil Solomon · 3 min read

Imagine a family where a mother in the United States has a trust for her two children. One child plans a winter in Lisbon. The other is thinking about a long stay in Bangkok. Both ask the same thing: how many days before the new country treats me as a resident?

The answer matters because residence is usually the switch. Once a country counts an heir as a resident, it may tax what a foreign trust pays out. Here is what the public tax pages show for the countries in our heir research.

Look at the first row more closely, because "183" hides small differences. Spain counts more than 183 days in a calendar year. Portugal counts more than 183 days in any 12-month period. Colombia counts 183 days inside 365 consecutive days. Ireland adds a second route: 280 days over two years, with at least 30 in each. Brazil starts the clock on day one for someone on a permanent visa, and uses 183 days in 12 months for a temporary visa. Singapore looks at the calendar year before the year of assessment.

Where there is no day count, the tests look at life instead of the calendar. Mexico asks whether a person has a home there and the main centre of their life interests there, with more than half their income from Mexican sources as one marker. France asks about the home or main place of stay, the place of professional activity, and the centre of economic interests. The Netherlands looks at facts and circumstances such as home, family, work and registration, and the PwC page says a single person staying more than a year is generally resident. In Greece the page speaks of presence in any 12-month period and the main ties. In Malta it speaks of ordinary residence and domicile. Japan uses a home, or an abode of a year or more.

Spain adds a point that touches the whole family. Residence is presumed where the spouse who is not separated and the minor children live in Spain. An heir with a young family there may be a resident for tax before counting a single day.

You might say: "I will stay under the number and I am fine." The tables above show why that may not settle it. In Spain, a main base of economic interests can make a resident of someone under 183 days. In Cyprus, one source describes a 60-day route for someone with a permanent home and local work. In Thailand, 180 is lower than most people guess. The day count is one door in. The ties test is another.

You could keep a simple calendar of days in each country for any year an heir moves around. You could also write down where the home, the bank accounts, the spouse and the children are, since those are the facts the no-count countries read.

Some readers have crossed the line without meaning to, through a long winter or a child who settled. Where did the line sit for you, and what told you? Share it here. Another family may be one month from the same line.

Figures are estimates for planning, based on public data. Date read: October 2026.