What makes physicians & surgeons different from an ordinary filing?
Physicians moving between systems carry a professional corporation or practice that does not travel with them: the entity remains taxable where it was resident, while the doctor becomes taxable where they now work. An ordinary preparer applies the general rule and stops there, which is how the relief in the specific provision goes unclaimed.
Can you work with my existing accountant?
That is how most of these engagements run. They keep the domestic file, we take the cross-border piece, and the boundary is agreed in writing so nothing is done twice or missed.
My medical corporation is in another country, so where does it pay tax?
Where it is resident, which is not necessarily where it was incorporated. Most systems look at where the company is in fact managed and controlled — where the decisions are taken, not where the certificate was issued. A professional corporation left behind when the doctor moves therefore often becomes resident in the new country by the simple fact that its sole director now lives and decides there, while the country of incorporation continues to assert its own claim. Two residences means two sets of filings and, in the worst arrangement, an exit charge as well. This is settled by looking at how the company is actually run, and it is much easier to arrange before the move than to argue afterwards.
I do locum work in two countries, so how do I split the income?
By where the work was physically performed, in the first instance. Employment and personal services income is generally taxable where the duties are carried out, so a week of locum sessions in one country is that country's income even if you live elsewhere and are paid elsewhere. The country you are resident in then taxes everything and gives credit for what the other was entitled to take. That works provided the split is evidenced. Keep the session records, the rota and the remittance advices by location, because the allocation is a question of fact and the party able to prove it is you. An allocation offered without records is the one that gets reopened.
Does my professional corporation become resident where I now live?
It can, and doctors are frequently caught by this because the company has one director and that director has moved. If board decisions, banking, contracting and billing direction all happen in your new country, that is a strong case that the company is managed there, whatever the incorporation documents say. Appointing a local director in the old country does not fix it unless that person genuinely exercises the decisions. Where a treaty exists it may allocate a single residence between the two claims, but the outcome depends on the facts as they actually stand. Decide deliberately how and where the company is to be run, then run it that way and keep the minutes to show it.
Which country taxes my partnership share in a medical practice?
Usually the country where the practice carries on its business, because a partner is generally treated as carrying on that business personally through the partnership and a clinic is a fixed place of business. Your country of residence then taxes the same share and gives credit. Two complications are common. The first is characterisation: some countries look through the partnership to the underlying income while others treat the distribution as its own category, and a mismatch can leave credit unavailable. The second is timing, where the partnership's accounting period does not match either tax year. Both are manageable if the position is set once and applied consistently, rather than being decided afresh each filing season.
My hospital says I am resident and my accountant says I am not, so who decides?
Neither of them. The hospital's view drives its payroll withholding, the insurer's view drives cover, and the licensing body's view drives registration, but none of those determines your tax residence. That is decided by each country's own residence test applied to the facts of your life — home, family, ties, days present — and where both countries conclude you are resident, by the treaty's tie-breaking tests. The practical problem is that a payroll operated on the wrong assumption still deducts tax, and recovering it takes a filing. Settle the residence position first, in writing, then instruct the hospital's payroll and your insurer from that single answer rather than letting three parties assume three different things.
Can I keep billing through my corporation after I move abroad?
Sometimes, but three tests have to be satisfied and they are separate. The health system or the payer decides whether it will continue to remit to that corporation at all. The regulator decides whether a non-resident may own a professional corporation in that jurisdiction. And the tax rules of the country you move to decide how it treats a foreign company you control, which in several systems means its profits are attributed to you as they arise, whether or not anything is distributed. Continuing to bill through the company is a defensible plan once all three have been checked. Continuing because nothing appeared to change is how a doctor accumulates unreported foreign company income.
How do you avoid double taxation?
You claim relief once, in the right country, in the right order. Usually the source country taxes first, the residence country then gives a credit for that tax against its own charge on the same income, and a treaty caps the source-country rate. Getting the order wrong is what produces a double charge you then have to unwind. The mechanism differs by income type, which is why we map the whole position before filing either return. See how to avoid double taxation.
What is cross-border tax?
Cross-border tax is what applies when income, assets or people touch more than one tax system at once — someone living in one country and earning in another, a company selling or hiring abroad, a family holding property in a second country. The work is rarely one country's rules applied harder; it is reconciling two sets of rules and claiming the relief that stops the same income being taxed twice at full rates. See what we do.
