[3rodents]

You are categorically incorrect.

Picking a random country: Italy. Please explain under what legislation or mechanism an Italian citizen who spends 3 months in Japan, 3 months in South Korea, 3 months in the U.S., 3 months in Norway and then repeats the loop for the rest of their life would owe any taxes to any tax authority?

Almost every country except the United States only taxes their residents, not citizens. Almost every country follows the typical 180 day rule for tax residency.

[fer]

Funny pick, because Italy is very strict on this. To stop being considered a tax resident in Italy you need to deregister from your municipality and register in the AIRE (Anagrafe degli Italiani Residenti all'Estero). But for the AIRE to accept your application on the Italian consulate in any of those countries you need to provide proof of permanent residence (address, work contract, company ownership, etc). If you don't do that, you're still considered resident of Italy for tax purposes, if you do it, congrats you're tax resident elsewhere. Registering in the AIRE is mandatory if you move, btw.

If you add the legislative decree 209/2023 article 1 that modifies the tax code and sets the basis for the centre of vital interests, it complicates things even further for the "permanent traveler" for simply having a family or ever having been long term resident in a country.

[3rodents]

Let's pretend my random country generator didn't pick the worst possible example. I should have chosen a country I am familiar with. Let's take Germany. A German tax resident can de-register at any time, so long as they are leaving the country, without first establishing tax residency elsewhere.

[fer]

In Germany, unregistering doesn't require registration elsewhere, but it doesn't mean you stop being tax resident.

If you regularly return to Germany and generally to the same place there (i.e. family, friends), and you're not tax resident elsewhere, the tax administration will consider it your habitual abode. And, you guessed it, under the German Fiscal Code (Abgabenordnung), you are a tax resident if you have a domicile or habitual abode in Germany.

Plus, under Extended Limited Tax Liability (Erweiterte beschränkte Steuerpflicht), any significant economic presence in Germany (assets, German clients, participation in a company, bank accounts) will pull you into the tax jurisdiciton for 10 years, not only as permanent traveler but also if you move to a low-tax country.

So while different, it's similarly difficult. It's technically possible but you have to leave Germany and basically cut all ties, difficult if you're German.

If you're not German, you can completely escape the claws of the German fisc with relative ease. But if you're say Spanish, Hacienda will consider you tax resident in Spain even if you never ever lived in Spain (i.e. born abroad). There's all sort of sticky tax rules in numerous countries: you're tax resident until you prove you're tax resident elsewhere, the aforementioned nationality fallback, essential ties rules, the "domicile" concept (i.e. where you intend to live until you die).

Plus, and I reiterate, the difficulty in obtaining a simple bank account without a TIN and proof of address in most countries.

I'm sure there are corner cases with exotic nationalities and carefully selected tax jurisdictions with lax "tax residency" tests to rotate along, and numerous nomads fly under the radar for various reasons (illegally of course), but I assure you it's way more complicated than "lol just don't be American/Eritrean and travel all the time", plus tax laws constantly change, and not to leave you more loopholes.

[3rodents]

> Plus, under Extended Limited Tax Liability [...] bank accounts [...] Plus, and I reiterate, the difficulty in obtaining a simple bank account without a TIN and proof of address in most countries.

You're doing what so many people who make this argument do. You're taking an extreme example that laws have been crafted to tackle and using it to represent the norm. A normal German citizen with a normal amount of money leaving Germany to become a nomad and travel the world, never establishing tax residency in any other country, will not need to open a bank account anywhere else, nor will they be subject to Extended Limited Tax Liability which is designed to capture tax from people who try to terminate their tax residency before realizing substantial gains on local assets. Completely irrelevant to almost every person on earth.

My original assertion is that unless you are American (or, apparently, Italian) the normal person can up sticks one day and wander the world, and so long as they never establish tax residency anywhere, they will be living an entirely legal tax free[1] life. Of course doing so requires giving up the things humans need, like stability, so it is a terrible life for most, but the point is, it is legal and easy.

> [...] and numerous nomads fly under the radar for various reasons (illegally of course), but I assure you it's way more complicated than "lol just don't be American/Eritrean and travel all the time"

"illegally of course" again, false. There is no universal tax law that we are all subject to. The Common Reporting Standard is intended to combat tax evasion. A person who does not have tax residency is not engaging in tax evasion, they are just a person without tax residency.

Rather than speak in theory and hypotheticals, can you point to any real world examples of someone being charged / tried / accused of tax evasion because they didn't have tax residency?

> plus tax laws constantly change, and not to leave you more loopholes.

Why are you framing it as a loophole? Not having tax residency isn't a loophole, just as not having a car isn't a loophole for a drivers license.

Despite my argument, I am pro taxation. Taxation is needed to support society. We pay taxes to contribute to the society we are a part of. Taxation isn't punitive. But if someone opts out of being a part of a society, if they choose to wander the world, without the benefits of having a home and community, why would they be expected to pay taxes? And to who? Tax residency is a good system, a fair system.

[1] tax free is a bad term anyway because tourists pay consumption taxes but we're talking about income taxes

[fer]

> A normal German citizen with a normal amount of money leaving Germany to become a nomad and travel the world, never establishing tax residency in any other country, will not need to open a bank account anywhere else

That will make you tax resident in Germany as all of your financial interests are in Germany. It's not an extreme example at all, it's the basic case to catch.

>My original assertion is that unless you are American (or, apparently, Italian) the normal person can up sticks one day and wander the world, and so long as they never establish tax residency anywhere,

Or Spanish. Or Belgian. Or French. Or Germany. Or basically any OECD country, and most non-OECD ones.

>they will be living an entirely legal tax free[1] life.

Legal as long as they don't generate any income, and even then, wealth taxes could kick in.

>Of course doing so requires giving up the things humans need, like stability, so it is a terrible life for most, but the point is, it is legal and easy.

It's really not easy at all to do legally, but at least we agree it's difficult to do emotionally.

>"illegally of course" again, false. There is no universal tax law that we are all subject to.

That's the fun part: virtually all OECD tax laws are universal.

>The Common Reporting Standard is intended to combat tax evasion. A person who does not have tax residency is not engaging in tax evasion, they are just a person without tax residency.

That's sovereign citizen tier of delusional. Plus I proved again and again that tax residence isn't bound to only where you are/live, at all, for over a decade, for any developed country and most developing ones.

>Rather than speak in theory and hypotheticals, can you point to any real world examples of someone being charged / tried / accused of tax evasion because they didn't have tax residency?

https://www.bbc.co.uk/news/entertainment-arts-67472496

She played the "I didn't stay anywhere for too long lol" card because she was touring most of the time, and she was slammed by the Spanish fisc on the basis of her centre of vital interests.

Literally most rock/pop stars would be living tax free if what you said was true, unfortunately for them it's not the case.

You won't find many high profile cases because the people who make money use expensive tax advisors who tell them not to do what you suggest, but since you're familiar with Germany, here's another: https://www.theguardian.com/world/2002/oct/25/germany.tennis

> Why are you framing it as a loophole? Not having tax residency isn't a loophole, just as not having a car isn't a loophole for a drivers license.

Not having a tax residency prevents you from legally doing business pretty much anywhere where it's worth doing business. I have to ask for a work visa in some countries I visit because of work even if there's a tourist visa-free regime for me, I literally am not allowed to do any work there. Would they notice? Probably not. But what happens if they do? That I and most importantly my company are in deep shit.