Welcome to another deep dive into Geo-Arbitrage Topics that can save you thousands…or in some cases…millions.
What inspired me to write this article was a member of the Retire with GEO-FIRE community. The member moved to Panama and went through the process of leaving the Australian tax net and moved permanently to Panama. But then made a series of small mistakes that have weakened his story that he has permanently moved abroad. The member could no be at risk of being pulled back into Australian tax residency and being taxed on the gains they made on their share portfolio (7 Figures). Their not the only one.
Let’s jump into it.
Former French footballer Samir Nasri reportedly declared himself a tax resident of Dubai.
The French tax office allegedly looked at the situation and responded with something close to:
“Interesting theory.”
Then reportedly built a case arguing his real life was still centred in France.
One of the headlines?
212 Deliveroo orders sent to Paris in a single year.
French authorities are reportedly pursuing more than €5.5 million in taxes, penalties and interest while arguing that despite the Dubai residency setup, his actual centre of life remained in France.
And honestly?
This story perfectly captures the biggest misunderstanding people have about international tax residency. People think tax residency is just paperwork.
But even Shakira, can tell you it’s not. It is about your behaviour.
Governments No Longer Care About Your Instagram Bio
A surprising number of people think international tax planning works like this:
- Move to Dubai or Paraguay
- Rent apartment
- Get residency card
- Post rooftop pool photo
- Never pay tax again
That is not international tax planning.
That is tourism with confidence.
Real tax residency planning is about proving your life genuinely moved. It’s also complex with layers of law, treaties and nuance that you need to be aware of.
Governments globally are becoming significantly more aggressive at determining where people actually live.
Not where they claim to live.
Your Lifestyle Leaves Evidence Everywhere
The important part about the Nasri story is not really the Deliveroo orders.
That is just the funny headline.
The real issue is the broader behavioural pattern authorities reportedly examined:
- flight records
- work obligations
- property use
- time spent in France
- digital activity
- economic interests
- recurring lifestyle behaviour
The Deliveroo orders simply became symbolic of something bigger:
His routines still appeared French.
That is the part people miss.
Modern tax residency investigations increasingly focus on:
- substance
- behavioural consistency
- lifestyle patterns
- economic ties
- habitual behaviour
Not just where you say you reside but, where you actually live.
The “Centre Of Life” Problem
Many countries like the UK, Australia and New Zealand apply some variation of:
- centre of life
- habitual abode
- ordinary residence
- economic interests
- domicile
- substantial ties
Different terminology.
Same underlying question:
Where is your real life actually located?
Because if:
- your family remains somewhere,
- your routines remain somewhere,
- your social life remains somewhere,
- your spending remains somewhere,
- your business remains somewhere,
…then tax authorities may argue YOU remain somewhere too.
Even if your residency card says otherwise.
Why This Matters To Australians
Australians are particularly exposed here because Australia has historically operated one of the broadest and most subjective tax residency systems in the developed world.
The ATO has long examined:
- behaviour
- intention
- accommodation
- family ties
- employment
- economic interests
- ongoing connections
It’s not just a case of counting your 183 days in Australia anymore. Those days are long gone.
Which is why many Australians unknowingly weaken their own non-resident position after successfully leaving.
Usually slowly, accidentally and through their behaviour.
The Dangerous “Half-Exited” Australian
This is probably the single biggest residency trap I see regularly.
The person who says:
“I left Australia permanently to live the good life in Bali.”
…but emotionally, financially and behaviourally never really leaves.
They:
- return constantly
- stay with family
- keep their old routines
- continue operating from Australia
- spend long periods there
- use Australian systems
- maintain Australian behavioural habits
Eventually their life starts looking split.
And split lives create residency risk.
You should always be aiming to tell a consistent story. That story needs to demonstrate to the ATO that you are permanently living outside of Australia.
The Future Bright-Line Risk
Australia has discussed various versions of bright-line residency tests over recent years, including models involving roughly 45 days combined with broader connection tests.
While implementation has shifted politically over time, the direction is obvious:
Governments want clearer tools to pull people back into residency where substantial Australian ties remain.
That means behaviour matters more than ever.
Because many people focus entirely on:
“how many days?”
while ignoring:
“what story do my actions tell?” These actions are the things the ATO would be looking for when determining if you’re really living abroad permanently or if perhaps you should be re-classified as an Australian tax resident.
Things That Can Pull You Back Into The Australian Tax Net
None of these alone automatically makes you an Australian tax resident again.
But collectively?
They can become dangerous.
1. Returning To Australia For Long Periods Repeatedly
This is one of the biggest risks.
Especially if:
- your visits become longer,
- more frequent,
- or increasingly routine.
At some point Australia stops looking like:
“a country you visit”
…and starts looking like:
“your real base.”
Particularly if your overseas presence weakens at the same time.
This risk has become increasingly relevant recently, with reports emerging of expats returning from the Middle East during periods of instability and potentially creating unintended Australian tax residency issues after years overseas.
2. Declaring “Returning Resident” On Arrival Cards
This sounds minor.
It is not.
If you previously established your position based on:
“I permanently departed Australia”
…then repeatedly declaring yourself as a returning resident creates contradictory evidence trails.
Your paperwork should align with your residency position.
Consistency matters.
3. Using Medicare As Your Practical Healthcare System
This is a major behavioural indicator.
Many people leave Australia claiming non-residency while continuing to:
- use Medicare regularly,
- rely on Australian healthcare systems,
- and treat Australia as their healthcare home base.
The issue is not occasional emergency use.
The issue is maintaining Australian systems as your primary fallback infrastructure.
Some expats prefer paying privately during visits specifically to avoid reinforcing Australian behavioural ties.
4. Staying Primarily In Family Homes
This is a massive one.
Especially if:
- you always stay at the same property,
- keep belongings there,
- have your own room,
- receive mail there,
- or treat it like your ongoing base.
That can begin looking less like:
“temporary visits”
…and more like:
“maintaining an ongoing Australian home.”
Many experienced expats instead:
- use Airbnbs,
- hotels,
- or short-term accommodation
while retaining records supporting temporary presence.
Righto, there are the other tripwires that could get you in trouble with the ATO..and this is exactly why I created the Australian Tax Residency Escape Plan 2026