Dual Citizen/Resident (EU & USA) — Tax Implications & Options

Now,

This matter does not change too much from country to country - i mean, taxing :

You incur taxes where you physically reside, if you work there.

Ie, if you work IN spain, even for your american company and accrue an income from your activity and this income is paid to you, then you are liable for taxes here. As an individual.

If, you dont get paid for anything, but you still incur income from your company in usa, you will be liable for taxes if you got this salary paid to you, if it is not taxed already in usa. If it is, then you can go through treaty to prevent dual taxation, and avoid getting taxed again.

So basically if you work to incur income, that income is taxable where you were physically in during the time you worked. IF, perchance, through any weird provision, this kind of income is already taxed in usa, you maybe can apply dual taxation treaty there too. but i doubt.

If you dont work to incur income, and get paid anything different - ie dividents, 'owner's rights' etc, then you may get taxed in usa, or in spain, depending on the situation, the way your corp pays the dividend and etc - that you need to research.

I am at a loss on how you would be working here without registering that you are working here by the way - even if with eu citizenship you will still need to register yourself as working here, and therefore become taxable.

as far as i know income over 22,000 eu or something is taxed yearly.

however im not a lawyer, so you should research this stuff with a lawyer.

if you ask me i would just get 'employed' by the danish company and let them handle all the local paperwork and legal stuff.

Unity - I'm not sure I agree that its practical to always pay taxes in the country where you physically reside.

I lived in Argentina (renewing my tourist visa every 3 months) and paid US taxes in the past and about every ex-pat I knew did the same. 

Although, I left the US 18 months I only moved to Spain a couple of weeks ago.  During the last 1.5 years I haven't had a resident in the traditional sense.  I am on online marketer.  I spent a month backpacking through Nepal, 2 months in India visiting in-laws, a month on the beaches of Sri Lanka, etc.  Should I have paid taxes to each of those countries on my income earned from my USA based business that invoiced my USA based clients?  That wouldn't be very practical, would it?

I guess at the end of day I need to see an international tax attorney because the information I've been receiving in these forums is all over the place for some reason.

Thank you,
Rob

keeping your work activity in a different country while being in a country temporarily during the visa issued by that country (3 months shengen for spain for example) is something different, being staying in a country longer than visa duration (which makes you a resident) is different, and being a citizen in that country or having the rights of a citizen (regarding work, like eu citizen in spain) is different.

and yes, you must contact a lawyer.

most countries have a certain number of days that you have to be physically in the country per year to count as a resident (where I've lived, it's around 180 days in the year, although the US has other bizarre rules). If you're spending 2-3 months somewhere and then moving on, that doesn't count.