Lessons from the Pandemic: Towards new principles for tax residence of individuals and corporations
Where is your tax residence? A major concern for wealthy families is to navigate residence and mobility. With families running businesses in multiple jurisdictions, children being educated in foreign countries and people spending time in different countries in a given year, the question arises : Where is your tax residence? We have examinded the rules of 5 different jurisdicionts: Germany, Israel, Italy, Spain and the Netherlands. A discussion followed about the various preferential tax regimes in Europe and in Israel (Aliya regime, Beckham law, impatriate etc.) and their potential future. In addition, we discussed challenges of relocation in light of exit tax, continued income tax liability despite departure, step up of assets, inheriance and gift tax implications in Germany, Italy, Israel, Spain and the Netherlands. At the STEP Europe Conference in Luxembourg we also discussed the impact on family businesses if one or more family members do relocate.