Hi Daniela,
Thanks for starting this thread. Itโs a really interesting topic thatโs relevant for a lot of DNs. Although thereโs some good information in this thread already, there are also a lot of inaccuracies. So hereโs my attempt at clearing up some of those inaccuracies.
First, this is the best introduction to the whole PT thing Iโve come across (written by โStreberโ). Check it out.
As long as youโre no longer tax resident in any country (including country of birth, citizenship, but also others where youโve lived/worked/have a connection) according to those countriesโ domestic rules, itโs totally possible to be a tax resident of nowhere. Note that if you have a US or Eritrean passport (citizenship based taxation) or are born in a country with domicile based taxation (e.g. Australia, Canada, and quite a few more), youโll probably always be tax resident somewhere (you will always have a domicile, if you lose your previous domicile it reverts to where you were born). But lots (most?) countries donโt determine tax residency based on citizenship or domicile (including most European countries), so itโs not unlikely that youโll be in the clear.
Always make sure to get confirmations from previous countries where youโve lived for a significant amount of time (and been registered as tax resident) that they no longer consider you to be tax resident according to their domestic rules.
Being tax resident of nowhere doesnโt necessarily mean that you donโt owe any tax anywhere, however. Generally income (for legal and natural persons) is taxed both based on tax residency and source. If tax residency and source is not the same country, DTAs and unilateral tax credits usually step in to make sure you donโt pay tax on the same income to both. With no tax residency you wonโt be able utilize any DTAs, so income is generally taxed at source. This means that you wonโt be able to lean on a DTA to reduce the tax burden for income that, for example, is subject to a withholding tax (e.g. 30% for a lot of US source income). But even if your income is not subject to any withholding tax, then the country where you physically perform the work (even just for a day) can tax you on the corresponding income (according to their domestic rules). However, many donโt if you only stay in the country for a short while. And those that have rules in place to tax you from day one, often (usually?) donโt come after you in practice as long as you donโt work for a local employer. Itโs definitely a legal gray zone, but the chance of getting in trouble with the tax authorities in a country where you spent 2 month working from your Airbnb is miniscule.
If none of the above caveats apply to you, and youโre okay with being in the above mentioned gray zone, then thereโs nothing stopping you from being a true PT.
Still, @ORCA is right that establishing a tax residency can still be beneficial. It makes dealing with banks easier (although you wonโt get into trouble for listing your country of citizenship as your tax residency for CRS purposes, as long as youโre not a tax resident in your country of citizenship according to that countryโs domestic rules), and will open up opportunities to use their DTAs to lower your tax bill in other countries (where youโre tax liable based on source or withholding taxes). Like @Orca mentioned, Malta is definitely worth a lookโespecially if you have a EU/EEA/Swiss passport. In that case itโs super easy to register as a โself-sufficientโ resident there.
And although the number 183 days is often thrown around as a minimum requirement for being considered a tax resident (through being โordinarily residentโ) in Malta, thatโs not really the case. According to Maltese tax law, residing 183 days per year in Malta would make you โordinarily residentโ automatically, but it doesnโt define anyone spending less than 183 days per year as not โordinarily residentโ. If, for example, you spend parts of your winters in Malta, with the intention of doing so year after year in the regular course of your life, then case law suggests that you could be considered โordinarily residentโ and hence also resident for tax purposes in Malta. Plus, itโs in Schengen, so itโs hard to know how long you really spend in the country.
The regular disclaimer applies. Donโt trust what I or anyone else write in some internet forum. Assume weโre all dead wrong and have no idea what weโre talking about. Talk to professionals in those countries that might consider you to be tax resident there to make sure thatโs not the case.
Anyway, one classical challenge with a truly location independent life with no home base is whenever youโre asked for a utility bill or similar to prove your residential address (to open various financial or investment accounts, verify Paypal, etc). Often a bank statement will suffice, and many banks will let you change your address on file with them to anything you want, in any country. So just change the address on file for with of your current banks to whatever address you need the confirmation for, and download an online statement. BOOM, thatโs sufficient address proof for most situations.
Cheers!