I am seconded abroad but still receive a partnership share. Who taxes it?
Both countries may reach it, and not on the same logic. Your secondment salary is employment income, taxed largely where the duties are performed. Your partnership share is allocated to you by rules that look at the partnership's own affairs, its sources, its allocations and its year end, and those rules do not follow your movements. So the share can keep arising in the home country while you are working somewhere else, and the host country may tax it as well if its rules make you taxable on worldwide income once resident. Relief comes from the treaty and from credits, applied stream by stream.
Does my secondment salary get taxed twice?
It is often taxed twice at source and relieved afterwards, which feels much the same until the returns are filed. The host country usually taxes the pay relating to duties performed there. The home country may keep withholding, either because the payroll was never told or because you remain resident for part of the year. What fixes it is a credit or an exemption claimed in the country holding the secondary right, supported by evidence of what the other country actually took. Getting the withholding right at source is better than reclaiming later, but the reclaim route exists and is worth using.
My partnership keeps allocating me income while I am abroad. Is that correct?
Usually yes, as a matter of partnership law and tax allocation, even when it feels wrong. An allocation is made because you remain a partner with an interest in the results, not because you were in the room. What changes with your move is not whether the allocation happens but which country taxes it, how the partnership's sources are characterised in your hands, and what the host country makes of income it never saw paid to you. Ask the partnership for the allocation statement and the source analysis behind it. You cannot report the income abroad from a net figure alone.
Which country taxes my partnership income when I move mid-year?
It depends on the residence position for each part of the year and on how the partnership's year lines up with yours. An allocation arising after you cease to be resident at home is not automatically beyond that country's reach, because the source of the underlying income may still be there. An allocation arising before the move may still be caught abroad if the host country taxes on a full-year basis. The practical work is a timeline: residence dates, the partnership's year end, the date each allocation arose, and then the treaty article that applies to that kind of income.
My professional body assumes I am still resident at home. Does that matter?
Not for the tax test, but it can cause trouble anyway. Membership records, practising addresses and registration declarations are filed years apart from a tax return and rarely say the same thing, and a revenue authority reading them alongside your residency claim will notice. The same applies to an electoral roll entry, a home-country practising certificate or a directorship register. None of these decides residence; all of them become evidence in an argument about it. Before you rely on a departure position, look at what your own records say about where you are, and make any inconsistency deliberate rather than accidental.
Do I have to file in both countries during a secondment?
Commonly, yes. The host country will expect a return covering the employment income earned there, and the home country will expect one for as long as you remain resident or continue to hold income sourced there, and a partnership allocation is exactly that kind of continuing source. The two returns have to be prepared together, because the credit claimed in one depends on what the other assessed, and the order in which they are filed decides whether you are claiming relief or amending later to get it. Agree the sequence before either return is lodged.
Do I still file a US return if I owe nothing?
Yes. The filing obligation depends on income exceeding the threshold, not on tax being payable, and the reliefs that reduce the bill to nil — the exclusions and the foreign tax credit — are claimed *on* the return, so not filing forfeits them. Information reports about foreign accounts and assets are separate again and carry penalties even where no tax was ever owed. See US citizens abroad.
How do I actually stop being taxed twice?
In this order. Fix your residence under each country's own rules, and if both claim you, apply the treaty tie-breaker. Identify where each type of income is sourced. Read the article that covers that income type, because it decides who taxes and at what maximum rate. Then claim the relief on the residence-country return, with proof of the foreign tax. Most of the tax people lose to double taxation is lost at the last step, not the first. See how double taxation is relieved.
