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16.02.2026

Tax residency of an individual: How do different countries determine if you should pay taxes to them?

Each country has its own way of determining when you become "local" for its budget, and these rules do not always boil down to a simple count of days on a calendar. Experts from Futura Digital, partner Alexandra Kurdyumova and lawyer Nazar Volkov specifically explained for App2Top the unique approaches in Russia, Kazakhstan, the UAE, and Cyprus.

Disclaimer: This article is for informational purposes only and does not constitute legal, tax, or any other professional advice. Before making decisions based on the information provided, you must consider the individual characteristics of each case and consult with specialized professionals. The article does not address the tax burden that arises from insurance contributions applicable in different countries.

Russia

The case here is relatively straightforward. There is only one general criterion to determine if a person is a tax resident of Russia: 183 days. The general rule works as follows:

A person is recognized as a resident if they have stayed at least 183 calendar days within any 12 consecutive months. The day of arrival/departure is included in these 183 days.

! There are disagreements on when (at the date of income payment / by the end of the calendar year) tax residency status should be determined, but we will leave these out of this article. In the Kazakhstan example, we’ll show how this issue is directly addressed in the law.

In general terms, if you are a resident, Russia has the right to tax all your income, regardless of where it is earned worldwide (at rates ranging from 13% to 22% personal income tax under the general rule). If you are a non-resident, Russia may tax income from Russian sources — from working for a company in Russia, dividends from a Russian business, etc. — the personal income tax rate can start at 13% and reach up to 30%, depending on the income type.

Other rules for determining tax residency exist, but they apply in rarer cases when it comes to tax benefits under a tax treaty between Russia and another country, where you may be formally considered a resident of both Russia and the other country. In such cases, other criteria, particularly the "center of vital interests" criterion, become prominent, which we will discuss later.

How can one prove presence/absence over 183 days? Any documents, directly or indirectly proving your movements and stay in specific locations, can be used, for example:

  • passport copies with border control stamps;
  • hotel accommodation receipts;
  • boarding passes, and so on.

Additionally, on the tax website, you can obtain documents that confirm your tax residency in Russia or conversely confirm that you are a non-resident of Russia (if you provide a tax residency certificate from another country).

Kazakhstan

Kazakhstan’s internal law also applies the 183-day rule. It operates similarly to Russia’s rule but with clarifications:

The 183 days are counted according to any consecutive period of 12 months ending within the calendar year. For instance, if you were in Kazakhstan from March 2025 to February 2026, by the end of 2026 you would be recognized as a tax resident of Kazakhstan as the period from March to February ended in 2026 and you were in Kazakhstan for 183 days within this period.

The 183-day period shortens for residents of the Astana International Financial Center to just 90 days.

Okay, let’s say you're not a tax resident by this criterion. But that's not where the story ends, as Kazakhstan's tax authority might recognize you as a resident based on the "center of vital interests" criterion.

In Kazakhstan, this criterion is represented in an abridged version as it requires three specific conditions:

  • you have citizenship/permanent residency/residence permit in Kazakhstan;
  • your spouse/close relatives live in Kazakhstan (if applicable);
  • you or any of your close ones have real estate in Kazakhstan, owned or rented, that is always available to any of you for living.

Why is this an abridged version? Because the original "center of vital interests" test contains no specific criteria—only guidelines that may indicate that a person has significant ties to a country. A similar test is implemented in the UAE, which we will analyze next.

If you are concluded to be a resident of Kazakhstan, Kazakhstan will claim worldwide taxation over your income. The personal income tax rate (analogous to Russian income tax) ranges from 10% to 15%. If you are a non-resident, only income from sources within Kazakhstan is taxed, and the rate can reach up to 20% for non-residents.

UAE

In the UAE, there is no personal income tax unless income is from business activities and/or earned from real estate/private investments.

Therefore, examining the residency determination approach in this country is particularly interesting: residency opens the possibility of legally not paying tax in the UAE and benefiting from tax treaties with other countries where you might earn income from.

The approach in the UAE is similar to what we see in Russia and Kazakhstan. Of course, there are some peculiarities.

1. 183-Day Criterion. This is standard and analogous to the Russian rule.

2. 90-Day Criterion. This is a shortened version of the 183-day criterion: you can obtain resident status by staying in the UAE for only 90 calendar days within 12 consecutive months.

Entering into this criterion requires several conditions:

    • having a Residence Permit in the UAE (a visa allowing you to live in the UAE, i.e., not a tourist visa);
    • having a permanent place of residence in the UAE / you have work or a business in the UAE.

A permanent place of residence is considered a place that is actually available and stably used by you. This means you must have evidence showing that (1) you have lawful access to an apartment (e.g., through ownership - title deed, or long-term lease - ejari), (2) you actually use the apartment (not subletting), you have the keys, and pay for utilities.

If there is no permanent place of residence, but there is an employment contract with a company in the UAE or your own business, you can also be recognized as a resident of the UAE by the 90-day criterion.

3. "Center of Vital Interests" Criterion. Even if you do not meet the 183-day and 90-day criteria, there remains a flexible criterion.

According to this, a person may be a resident if they meet both of the following conditions:

A) They have a usual or predominant place of residence in the UAE. Unlike a permanent place of residence, a usual or predominant place of residence concerns the country where a person usually lives, not tied to a specific dwelling.

B) They have a center of financial and personal interests in the UAE. Any circumstances showing a person's interests may be considered:

    • place of work/business;
    • where bank accounts are open;
    • place of investments and managing them;
    • where spouse, family, friends are located, relationships with them; this part may even consider the location of pets;
      where a driver's license is issued;
    • membership in associations;
    • participation in cultural and other activities.

Note that in practice, relying on the 90 calendar days criterion (let alone the "center of vital interests" criterion) may be difficult if you want minimal ties with the UAE and still use tax advantages present in this country. There is a high likelihood that the tax authority (UAE or foreign) will deny residency recognition if circumstances show you've moved to the UAE merely for tax benefits. In any case, the decision is made on a case-by-case basis and also depends on the country from which you receive income, not just the UAE approach.

If it is concluded that you are a UAE resident, the UAE tax authority can issue you a UAE tax residency certificate upon request as proof. There are two types: (1) for internal purposes, (2) specifically for showing overseas tax authorities and applying benefits under tax treaties.

Cyprus

Let's move to Europe and look at Cyprus’s approach— a classic haven for the gaming industry — to determining residency.

  1. 183-Day Criterion. Standard here and similar to the Russian rule.
  2. 60-Day Criterion. Applied if the following conditions are met:
    • you stay in Cyprus at least 60 days in the current calendar year. The day of departure from Cyprus is counted as a day out of Cyprus;
    • you didn't stay in any other country for more than 183 days in the year;
    • you have a business/job in Cyprus/you are a director in a Cypriot company;
    • you have a permanent place of residence in Cyprus (similar to how this rule works in the UAE).

If you are a resident, Cyprus can claim all your worldwide income. Cyprus uses a progressive tax scale, depending on the income amount, with rates reaching up to 35%.

While in Cyprus, expats have a benefit for those with Non-Domicile status: these individuals are exempt from the defense contribution and from tax on dividends and certain other income for 17 years.

Resident Nowhere?

Among nomads, there's this popular idea: if you don't stay long anywhere in any country, you can, in theory, not pay taxes at all. On paper, this seems like an ideal setup, but it has its problems in reality:

you need to consider your passport, as some countries still consider you obliged to pay taxes even if you haven’t lived there for a long time but retain their citizenship (e.g., the USA);

taxes in income-source countries do not disappear: you will still earn income from some country, and countries often apply a withholding tax in such situations (i.e., the payer deducts tax before paying income to you). As a result, you may face (1) higher tax rates (e.g., for non-residents of Russia, payments can reach 30%, and the same applies to payments from the US), and additionally, (2) you may not be eligible for tax treaty benefits as these require residency status somewhere to apply;

some countries (e.g., the UAE) have a "center of vital interests" criterion to recognize you as a tax resident, thus, in such countries, there's still a risk of being obligated to pay tax as a resident;

there's a risk of issues due to bank accounts. Banks must share information under the automatic exchange standard (CRS) with government authorities who then pass this information to counterparts in other countries. So, there’s a chance your income information will be sent to the country listed in your profile. The tax authority in this country may then require you to pay tax on this income.

Thus, being such a "tax ghost" carries a higher risk of excessive or sudden taxation. Perhaps in your case, it might be more advantageous to choose a country with comfortable taxation and a robust network of tax treaties. However, before doing so, of course, you need to analyze the conditions for being recognized as a tax resident in that country and the tax implications of such recognition.

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