Eli5:How do people with dual citizenship pay taxes?

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Do they pay taxes to both the countries they have citizenship of or the country they reside in.

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Anonymous 0 Comments

There’s a lot of bad information here. In the past tax collection in various countries were known as “inland revenue” or “internal revenue” referring to tax collection stopping at your countries borders and indeed the IRS is still somewhat erroneously so named. Taxation is more complex as people in the past and currently have exploited loopholes in international taxation and governments have broadened tax laws to shut these loopholes down and collect more taxes.

The situation today is that you do have to **check the rules of both countries** that you have citizenship in as well as the country that you are doing work in (you could be a dual citizen working in a 3rd country). Leaving aside oil rigs and cruise ships you are often are required to file taxes in both countries. There are exemptions, allowances or different rates of taxation compared to normal salaried people that may apply to you and whether there is a gross tax liability. It is a regular situation that you can be assessed for taxes in both countries on the same money (and at different tax rates). Furthermore different laws and rules apply as to whether you are **Tax Resident** – your status of which can be different from your citizenship.

However there is tax relief and for this you need to look at the **Double Taxation Agreement** between the 2 countries. These agreements are country specific and no-one should give you general tax advice without checking the specific agreement.

These are the UK USA current DTAs [https://www.gov.uk/government/publications/usa-tax-treaties](https://www.gov.uk/government/publications/usa-tax-treaties)

What you can often find in a DTA is rules regarding **Tax Credits**. This means that PAYE and other taxes paid to one country may be recognized in another country. So you can work in country A, have to declare that income in both country A and country B, but you also get to recognize the tax already paid in country A both jurisdictions.

Also a note every country has it’s own tax year so don’t assume that it’s by calendar year:

UK = 6 April to 5 April
USA = 1 Jan to 31 Dec
South Africa = 1 March to 28 February
Australia = 1 July to 30 June

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