How tax residency is determined in 2026: the 183-day rule, centre of vital interests, mind-and-management for companies, dual residency and treaty tie-breakers, and how founders actually change residency versus merely relocating.
Tax residency decides which country may tax your worldwide income — and it is almost never the same thing as a visa, citizenship, or passport address. Founders routinely relocate physically while remaining residents of their old country, triggering tax where they did not expect it. This guide covers how residency is really determined and how to change it defensibly.
The Russian-language edition of this operator guide is the canonical version; this English summary mirrors its structure.
Residency is not the visa: it is determined by facts — the 183-day rule, centre of vital interests, and, for companies, mind-and-management (place of effective management). Dual residency is resolved by the treaty tie-breaker (permanent home, vital interests, habitual abode, nationality, mutual agreement) — but only where a treaty is in force; many CIS treaties are suspended. Changing residency means severing ties with the old country and building them in the new one, watching for exit tax, and synchronising company substance with the founder's residency.
See the full Russian guide for the founder traps and the step-by-step relocation walkthrough.
INNOVA CG structures personal and corporate residency changes as one project: tests, tie-breakers, exit tax, and substance alignment.
This material is for general information only and does not constitute legal or tax advice. Accurate as of the publication date.
