• Data on border crossings will be transmitted to the Federal Tax Service (FNS), where an individual’s tax status will be automatically assigned based on the results of the calendar year.

• An individual’s status may not be final, since after the application of Article 4 of the relevant DTT (double tax treaty), exclusive tax residency may not coincide with residency under domestic law. For example, a person spent more than 183 days in the Russian Federation during a calendar year, while the family is in Spain and the main income was earned in Spain. In that case, Spain will be the place of tax residency, despite the FNS data showing presence in the Russian Federation for more than half a year.

• In addition, theoretically, difficulties may arise in correctly determining tax residency when different passports are used at border crossings (for example, leaving on an Israeli passport and returning to the Russian Federation on a Russian passport). Although when crossing the border with two passports, it is recommended to use the Russian passport when entering and leaving.

  
  

Thus, the system may not always allow tax residency to be determined correctly.