Tax Residency: How It Is Determined and How to Change It in 2026

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.

Tests, tie-breakers, and changing residency

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.