Get to know personal income taxes, how they are calculated in different countries, and why it's important to have a personal tax strategy
If you’re reading this, you’re probably wondering which country you owe your personal taxes in, and how you can navigate the complexities of paying personal income tax. You may also be wondering how working across borders affects your personal taxes.
Personal income tax can be quite different around the world in terms of what income is taxed, tax rates, and complexities regarding tax filing and compliance. Knowing where you owe tax is essential, especially considering that in some instances you could find yourself caught by double taxation, where more than one jurisdiction has a claim to your income tax.
As entrepreneurs, solopreneurs, digital nomads and startup founders are increasingly looking for opportunities to accelerate business growth, many people look at getting Estonian e-Residency. However, e-Residency itself should not be confused with tax residency – just as it should not be confused with the right to citizenship or physical residency.
Below we take an in-depth look at personal income tax and the benefits and implications of being an Estonian e-resident. As tax matters can be complicated and have far reaching impacts on your personal life, it’s important to seek advice from a professional tax consultant in any country where you live, work, or do business.
If you earn an income from a salary, investments, royalties, or real estate then you will most likely be liable for personal income tax. The tax rate you’ll pay and the regulations you’ll be subject to will vary, depending on where you are tax resident and/or have personal income tax liabilities.
Each jurisdiction has their own tax laws – with some countries not imposing any personal income tax (e.g. the UAE) and others levying a tax rate of up to 55.9% (Denmark).
Understanding tax laws in different countries can help you to optimise your tax liabilities and help ensure that you comply with all regulations. For e-residents, it's also important to understand the difference between your individual taxes and your company's taxes.
In general, you’ll owe taxes where you are a tax resident (except for income that is generally taxable at source regardless of tax residency, e.g. income derived from real estate). Every country has their own rules about who is considered a tax resident. This can make it quite complicated for the average person, particularly if you’re a digital nomad or you have a company in a different country from where you live, to figure out their tax obligations. It is advisable to get tax advice from a professional to ensure you’re tax compliant.
Some countries tax their citizens on their worldwide income, regardless of where they live (e.g. the USA), while other countries determine tax residency based on where you’re domiciled (even if you don’t necessarily live there). Many countries establish tax residency based on physical presence and where you spend the most time (which is often 183 or more days of the year spent in one country).
Because personal tax residency and which country you earn your money in influence where you owe tax – it’s important to consider your options and where you choose to spend your time wisely.
The calculation of personal income tax varies depending on the tax laws of the specific jurisdiction where you’re considered a tax resident.
In general, this is how personal taxes are calculated:
Depending on the tax laws in the country where you owe taxes, there may be several factors that affect how much tax you owe. This includes how much you earn, your marital status, whether you have dependents, the tax deductions and exemptions that you’re allowed to claim, and any tax credits that apply (e.g. possibility to deduct income tax paid in foreign jurisdiction).
Your personal income tax jurisdiction and rules that apply can significantly impact your financial well-being, especially as an entrepreneur or someone working internationally. Having an in-depth understanding of how personal taxes work and the factors that influence your tax liability is critical to help you make informed financial decisions and to maximise your income.
Below are five reasons to plan for your personal tax:
To optimise your personal tax liabilities, consider your tax jurisdiction options and the advantages of these options such as tax rates, tax exemptions, and tax credits.
Before moving to a no or low tax jurisdiction though, check first what other fees or costs you might need to pay to the government as a tax resident - for example, compulsory health insurance or real estate purchases, or even broadcast licensing fees. They might not be called taxes, but they will take a chunk out of your wealth. Also consider what services you might give up by moving to a country with low taxes (and therefore have to pay for yourself, often at higher premiums), such as healthcare, education, and transport.
Tax planning is an important step towards tax optimisation and tax efficient investing, which you can do with the help of a duly qualified tax professional. You'll find many tax experts on the e-Residency Marketplace, who have knowledge of tax laws in many jurisdictions as well as implications of working and running businesses across borders.
If you own a business and you’re paid a salary and or dividends, then understanding the personal tax implications of these incomes can help you to maximise your take-home income.
Depending on your business structure, for example operating as a sole proprietor vs as having a company, can have far reaching tax implications. If you have a company, make sure you understand how corporate taxes work. You might find that some of your personal investments, real estate or other assets earning income might be better structured under your company from a tax perspective.
If you owe taxes in a country that levies capital gains tax (CGT), it's good to be aware of this type of tax before making decisions about investing in or selling assets that are subject to this form of tax. Assets like stocks, bonds and property are often subject to capital gains tax (minimum holding periods or participation thresholds may apply for tax exemptions). The CGT rate can vary quite dramatically in different jurisdictions, which makes understanding CGT tax important for minimising your tax liabilities.
In Estonia, capital gains from the sale or exchange of assets are generally taxed on a net basis as part of ordinary income, but capital losses can only be offset against capital gains. Certain qualifying capital gains are exempt from income tax, such as the gain from the sale of a personal residence. Importantly for e-residents, certain capital gains realised by non-residents (e.g. gains linked with immovable property located in Estonia) form part of their Estonian-source income, for which they are liable for self-assessing 22% Estonian income tax and submitting a tax return to the Estonian tax authorities.
The impact of being taxed twice by two different countries that both have a claim to your income can be catastrophic. Countries like Estonia have double taxation agreements with a multitude of countries for this very reason. It’s vital to check whether your income can be taxed in more than one jurisdiction, so that you can plan accordingly.
Personal income tax can also affect your retirement planning. Some tax systems allow you to save towards a pension and claim a tax deduction and rebate; others allow you to defer your savings tax — helping you to accelerate your retirement savings. Knowing how your retirement savings will be influenced by your personal tax helps you plan for retirement and financial security. Speak to a qualified finance and tax professional to get advice on how to plan for your retirement.
Personal income tax systems are quite different from country to country. Some countries impose flat tax rates for everyone, while others have progressive tax systems with multiple tax brackets. Some countries impose very high personal income tax rates, while others have low or no personal income tax. Tax rates may differ depending on residency status of the recipient as well (e.g. higher rates for residents and lower rates for non-residents).
These examples below highlight just how different tax systems can be around the world:
There are many general advantages of becoming an e-resident of Estonia. E-Residency provides the opportunity to register a company in Estonia easily and relatively cheaply, manage it online from anywhere in the world with a secure digital ID, and operate in the EU marketplace.
Companies registered in Estonia are liable for company tax in Estonia – one of the most tax competitive countries in the world. Estonia’s favourable company tax regime also allows companies to defer paying any taxes by reinvesting profits, thereby fuelling company growth.
Estonia also has a large number of double taxation agreements with other countries, helping to minimise the chances of being taxed twice.
Furthermore, the business friendly environment, culture of entrepreneurship, support for startups, and efficient online business administration — have made Estonia a global hotspot for digital nomads, remote workers, startups and location-independent professionals.
Estonia's popular e-Residency program offers a pathway for entrepreneurs and business owners to locate and operate their businesses in Estonia without having to physically live in Estonia. In fact, e-Residency does not confer any residential or citizenship rights or tax residency rights.
Businesses operating in Estonia will typically be tax resident in Estonia (subject to CFC rules, permanent establishments in other countries, and taxation treaties). In contrast, e-residents of Estonia will generally not be liable to pay income taxes in Estonia as they will not be tax residents here. Of course, if they earn income taxable as non-resident’s income in Estonia (e.g. income from real estate or director’s fees for management of Estonian companies), they will have personal income tax liabilities in Estonia and must file a yearly individual tax return.
To determine where e-residents pay tax, it’s important to look at your citizenship, and where you live or spend most of your time, and what the source of your income is to ascertain your tax liabilities. As mentioned above, some countries impose a territorial tax system, while others tax their citizens no matter where they may live.
If a company in Estonia pays out a director's fee, then personal income tax (which is levied at a flat rate of 22%) and social tax (levied at 33% being the company’s tax obligation) is payable in Estonia – and that applies to residents and non-residents alike.
However, if a non-resident receives a director’s fee and their country of residence has an agreement with Estonia regarding social taxes or you live in the EU, EEA, or Switzerland, then you will be subject to the social security scheme of your country of residence (an Estonian company that pays directors' fees may be exempt from paying social taxes in Estonia). For residents of the EU, EEA and Switzerland, you will need an A1 certificate to avoid your company having to pay social tax in Estonia.
Managing your personal tax appropriately helps you meet your tax compliance obligations, plan for upcoming tax contributions that may be owing, and optimise your personal tax.
To manage your tax effectively, here are some useful tips:
Considering where you owe personal tax and the tax rules that apply can help you to plan ahead and ensure tax optimisation and efficiency. Tax planning can also help you discover the optimal place to be a tax resident and how to take advantage of options like Estonia’s e-Residency program.
Careful consideration should also be given to other taxes that you may be liable for, such as inheritance tax, wealth tax, or property taxes – as well as the cost of living, standard of living, and social security benefits associated with your place of tax residence.
Given the importance of tax on your personal finances, it’s advisable to get professional tax advice to help you achieve your financial goals.
Disclaimer
This article was written by guest contributor Andy Stofferis (www.andysto.com). Andy is not a tax or VAT expert and the article is not intended to give any legal or tax advice. Tax laws and regulations vary greatly from country to country, and this information is a general guide only. You are advised to contact a professional tax advisor for any legal or tax advice, and not to rely on this article as gospel.
