Remote work changed mobility, but it did not simplify treaty evidence
The OECD model shows the architecture of dual-residence analysis, and HMRC's residence guidance brings that architecture into practical filing life. The common remote-founder mistake is thinking a move announcement, a visa or a new lease settles the treaty question by itself. Treaty residence remains a sequence of factual tests, and the evidence needs to line up with that sequence.
The evidence file should mirror the tie-breaker tests
Permanent home, centre of vital interests, habitual abode and nationality are not abstract ideas. They point toward actual documents and facts: access to homes, family location, business control, travel patterns and where day-to-day life is genuinely anchored. That is why strong treaty files feel more like structured evidence packs than like personal essays about where someone 'mostly lives now.'
The safest cross-border habit is to document early while the facts are still easy to prove
A remote founder usually remembers the big move but not the small facts that later matter just as much. Travel days, board activity, home access and personal ties become harder to reconstruct over time. A disciplined treaty-evidence file built during the year is far more powerful than a hurried reconstruction after two tax authorities start asking questions.
Educational content only
This guide is for general education, not personalized tax advice. Tax rules change and your facts matter — confirm anything important with a qualified professional or the cited official source before taking action.