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The Cross-Border Wealth Playbook →
The Cross-Border Wealth Playbook · Free Tool

Who can tax this?

When you live across borders, the first questions are always the same: which country is your tax residence, and which country gets to tax each kind of income? This wizard walks the treaty tie-breaker and shows the usual answer, income type by income type — so you know which conversations to have before the tax bill arrives.

1 · Your residence
2 · The income
3 · One more thing
Your likely treaty residence
Resident in Country A
You told us you're resident in one country.
Who usually taxes this income first
How the overlap is relieved
Your residence country taxes worldwide income and relieves the other country's tax by credit or exemption.
How the answer is built

Two questions, in order: where are you resident, and where does the income arise?

If two countries both claim you as resident, a tax treaty's tie-breaker decides which one wins — usually in this order: where you have a permanent home, then your centre of vital interests, then where you habitually live, then nationality. Once residence is settled, the treaty allocates the right to tax each type of income between the two countries, and your residence country relieves the overlap by credit or exemption. Real estate is the great exception — it is taxed where it sits. And for US citizens, the saving clause lets the US tax them almost as if the treaty did not exist.

This is Chapters 1, 6 & 7 of The Cross-Border Wealth Playbook.

The three questions, treaties and tie-breakers, and the credit-versus-exemption methods — plus a treaty quick-reference appendix and a companion workbook that estimates the tax stream by stream. Get the chapters and the launch notice.

The treaty chapters + launch notice. No spam; unsubscribe anytime.
Educational orientation only — not tax or legal advice, and not a substitute for a qualified cross-border adviser. This wizard shows the typical OECD-model treaty pattern; the specific treaty between your two countries can change every answer, caps and conditions apply, relief usually must be claimed with a certificate of residence and the right forms, and some country pairs have no treaty at all. Confirm your residence and each income type for your specific countries and year before relying on it.
Educational references and tools — not legal, tax, accounting, or investment advice, and not a recommendation to buy or sell any security. Consult a qualified professional about your specific situation. © 2026 The Baratelli Institute.