@Steve *******

yes, you are 3 b), the fact that you have propertie and stock in a country don't go over that you live month per year in a country.

I try to make you think outside the box with different situation to make you understand by yourself your "strategy" 😆

@Steve *******

you totaly ignore the reverse situation i give you.

If i go to Dubai, pay 0% tax , i stay dubai 3 month per year and go Australia for 9 month per year, i don't need to report and pay tax in Australia ? realy ? ( i take Dubai as example without check if they have DTA with Australia, but you can select a other country low tax with DTA ) (thailand for example :')

@Steve *******

i don't ignore the DTA, the DTA allow to get lower tax on the source income ( for example dividend ) and allow to use it as tax credit.

For example, if the Company Coca send me dividend, i will pay 15% of america tax and not 30% because of the DTA, and if i remit it in Thailand, i can use tax credit of the 15% already paid for the thai tax.

@Steve *******

i repeat, think reverse, if a thai citizen go to Australia, and stay in Australia for 9 month, and go thailand for 3 months. Don't report tax and don't pay tax in Australia ? you think ? (because he has realestate and stocks in Thailand ??).

It will be a incredible tax hole😅

For the economic ties, it is more for people who go out of the country for > 6 months (to avoid pay tax in is main country), but have business, wife, children (young), it is more a protection to avoid abuse of tax system for a country ( it is more a exception, and it is a very bad situation because if the 2 country don't agree you may even pay full tax on both country ).

The thai tax officer i speak is the one that may control you because you stay more than 6 months in Thailand.

@Steve *******

the problem in your strategy is to explain to thai tax officer that you are not thai tax resident because you go holiday in other country for 2 or 3 months per year, but maybe with good paper, certificate of tax residency, .. you may go throught ( i have some doubt ).

In my country they will laught at me if i say i have Certificate Tax Residency in thailand, live 9 months in my country, go 3 month holiday in thailand, and not willing to complete and pay tax in my country where i spend 9 month/year.

=> reversing thing still don't give you some warning ?

@Steve *******

so if you get thai tax control in thailand, you will say that you are tax resident in Australia because you stay there 2 or 3 month per year ? and that you believe it make you that country tax resident because you chose it ?

@Steve *******

yes, and the main tie-breaker is where you spend most of the time. (some exception may occur for example if your economic activity is in the country you spend less of your time)

@Bob *********

you wait somebody come knock at your door ?

@Dean ****

where will be your tax resident ? most country tax worldwide income .. remited or not ...

@Steve *******

yes, example : up to you for your personnal case (stay month in your home) :

Application in Tax Treaties

Under a DTA, the "permanent home test" is often the first step in resolving dual residency. If a person is considered a resident of both Australia and another country:

The tax treaty looks at where the individual has a permanent home.

If permanent homes exist in both countries, other criteria (e.g., center of vital interests, habitual abode) are considered.

Practical Steps to Determine Your Permanent Home:

Review where you spend most of your time.

Assess the nature and stability of your living arrangements in Australia.

Consider where your family and personal belongings are located.

Look into whether the overseas residence is intended to be temporary or permanent.

If in doubt, consult a tax professional or the Australian Taxation Office (ATO) to confirm your residency status and obligations.