Does my professional corporation move with me when I practise abroad?
No. The corporation is a separate person and its residence is settled by where it was formed and where it is actually managed and controlled, not by where you happen to be treating patients. A professional corporation set up and administered in the country you left generally stays taxable there, while you become taxable where you now work. The two questions are answered separately, and the answer to one does not settle the other. The practical consequence is that you can end up filing personally in one country and for the entity in another, with income having to be attributed between them.
Am I taxed where the hospital is or where I live?
Both, usually, and in a set order. The country where the work is physically performed taxes the remuneration for the days spent there. The country where you are resident taxes your worldwide income and then gives credit or relief for what the other country properly charged. So the day-by-day location of your clinical work decides the first charge, and your residence decides the second. That is why a travel and rota record matters more here than a payslip does. Where your residence is itself in doubt, that question has to be settled first, because the relief mechanism depends on knowing which country is the one giving relief.
How is locum work in another country taxed?
Locum income is taxed where the shifts were worked, which is what makes it awkward: a doctor covering rotas in more than one country creates a source in each of them. Each country looks only at the days on its own soil and charges the fee earned there. Your country of residence then looks at the whole and relieves the overlap. Before any of that can be computed, the shifts have to be allocated to the right country and the right year, and agency statements rarely do this for you. Keeping a rota-level record as you go is far less work than reconstructing one afterwards.
Can my corporation keep billing for work I do abroad?
It can invoice, but invoicing does not decide who is taxed. If you personally perform the clinical work in another country, that country will look at where the service was rendered and by whom. It may treat the fee as yours rather than the corporation's, or treat the corporation as carrying on business there through you. Either outcome is a different filing obligation from the one you had before you moved. The useful step is to decide deliberately what the entity is being paid for and to document it, rather than letting the old billing arrangement run on unchanged into a new country.
My insurer and my college disagree about my residency — who decides?
Neither of them. A licensing body records where you are registered to practise, an insurer records where it will cover you, and a payroll department records an address. None of those is a residency determination. Residency for tax is decided on the facts that each country's own rules and the relevant treaty look at: where your home and family are, where your professional and personal life is centred, and in some cases nationality as a tie-breaker. It is worth reaching one documented position and then making the registrations, the cover and the returns consistent with it, rather than the other way round.
How is a partnership share in a clinic abroad taxed?
A partnership share is not salary, and it is usually not corporate income either. In most systems the partnership is looked through and each partner is taxed on their share of the profit, sourced where the partnership carries on its activity. So a doctor with a share in a clinic in one country, employment in another and residence somewhere else again has separate characterisations to get right before any credit can be claimed. The order matters: characterise the income, source it, then relieve the double charge. Doing it in the opposite order is how relief claims come to be refused.
Which countries have a tax treaty with the United States?
Around sixty, including Canada, the United Kingdom, India, Australia and most of western Europe — but the list matters less than the terms, because each treaty caps rates and allocates income differently. Two countries with treaties can produce opposite answers on the same pension or the same royalty. What decides your position is the specific article covering your income type. See our country guides.
How does the treaty tie-breaker work when both countries say I am resident?
As a sequence, stopping at the first test that gives an answer: where you have a permanent home available; if in both or neither, where your centre of vital interests is; then habitual abode; then nationality; and if all of those tie, the two tax authorities decide by agreement. It is evidential rather than elective — you do not choose your treaty residence, you demonstrate it, which makes the record of homes, family and time the substance of the claim. See tie-breaking dual residency.
