Mudança de Residência como Forma de Planejamento Tributário

Abstract

The article presented by Professor Zornoza is outlined in the research project DER2010-20000 financed by the Spanish Ministry of Economy and Competitiveness. It focuses on the impacts that changing residence may cause when used by taxpayers as a form of tax planning. In this paper, Professor Zornoza demonstrates that as tax treaties and domestic legislations become outdated for providing the proper treatment for current complex economic transactions, where capital and people easily circulate from one country to another; and considering that competition for inbound investment has led an increasing number of countries to offer reductions in their effective tax rates, taxpayers are able to manipulate their fact pattern in order to meet with the residence criteria of more than one jurisdiction, obtaining unexpected tax benefits from becoming resident either in more than one country or in no country at all