If you are planning a move abroad, you might assume tax residency is something you declare. Choose your country, tell the tax authorities, done. The case of former Arsenal and Manchester City footballer Samir Nasri shows why it does not work that way.
Many people planning a move abroad assume tax residency works like a declaration. You choose a country, you inform the authorities, and the matter ends there. The case of former Arsenal and Manchester City footballer Samir Nasri shows why that assumption fails.
Nasri told the French tax authorities he was tax resident in the UAE. The French authorities opened an investigation following accusations that he actually stays in Paris. Their evidence includes something unexpected. Investigators reportedly found that Nasri ordered 212 meals through the Deliveroo app to his Paris home in 2022 alone. (Yahoo Sports)
The argument writes itself. How does your main home sit in Dubai when you order that many takeaways in France?
The case involves serious sums. According to an investigation by French newspaper Les Echos, the authorities believe Nasri may owe more than €5.5 million, including €5.25 million in income tax for 2020 to 2022. The food orders form only part of the picture. Airline records reportedly show he spent between 126 and 208 days each year in France between 2021 and 2023, against 42 to 124 days in the UAE. Court documents also note his broadcasting contract with Canal+ and his ownership stakes in French companies.
Nasri disputes all of this. His lawyer has dismissed the figure as imaginary and insists his client declares his earnings properly and pays tax on income generated in France. The case continues, so nothing has been decided. Even so, the approach taken by the authorities carries a lesson for everyone. (Vanbellelaw)
We speak to people in similar situations all the time. Some say they plan to move to the UAE without really living there. They want the visa, the bare minimum of days, and their home base kept firmly in the UK. Others want the opposite. They hope to keep UK tax residence despite spending no time in the UK at all.
The system does not offer that choice. If residency were elective, everyone would pick the lowest tax jurisdiction and stay exactly where they are. So the framework rests on the reality of your circumstances instead. Where do you spend your time? Where is your home? Where do your cultural and economic ties sit?
Treaties add another layer. You can be dual resident under the domestic rules of two countries at once. The double tax treaty then decides which country takes priority, using tests built on those same facts. Arguing that your main home sits in Dubai becomes difficult when the delivery records tell a different story.
The Nasri case also signals something new about evidence. Residence audits once relied on traditional records such as border crossings, hotel invoices and bank accounts. Today our daily lives generate timestamped, geolocated data stored automatically by the platforms we use. A single food order proves your presence at an address at a specific moment. Hundreds of them build a timeline. (fotmob)
This cuts both ways. The same digital trail that undermines a weak residency claim can support a genuine one. That is why we always emphasise evidence gathering and record keeping. Keep your travel records. Keep your documentation. If the tax authorities ever examine your situation, the facts should speak clearly in your favour.
This case sits between France and the UAE rather than the UK. The principle travels, though. Wherever you move, your residency position rests on how you actually live, not on what you say.
If you are planning a move abroad, or returning to the UK, an early conversation makes everything simpler. We will help you understand your position and build the evidence to support it. Book a consultation with LSR Partners today.
LSR Partners help you pay the right tax in the right place at the right time.
If you are considering a move and want to understand how it affects your UK tax position, book a call with us at lsrpartners.com. LSR Partners help you pay the right tax in the right place at the right time.
This article is for general information purposes only and does not constitute tax advice. Please contact us to discuss your specific position.
