Peter wrote:
So where exactly does residence come into this? Does non-residence exempt you from having to pay import VAT?Exactly. If you don’t have a residence in Switzerland, you can fly any plane into Swiss territory without the need to declare it at a customs airport. You can even use small airfields with customs O/R when coming from another Schengen-country, because you don’t have to declare your airplane for temporary import. You only need to declare a temporary import if you’re a Swiss resident. This is also valid for the opposite case: A EU-resident flying a Swiss plane – which is only taxed in Switzerland – into the EU must declare it for temporary import at an official airport with customs. A Swiss resident can just fly to any airfield with customs O/R, because he doesn’t need to declare the aircraft for temporary import. How to solve this problem? Pay VAT of one airplane in both EU and Switzerland and keep copies of the tax invoices in the airplane.
Now, what about a Swiss resident ferry pilot, flying an N-reg from the US to Botswana, and landing at LSZH to refuel?Thats not a problem when you don’t leave the airport, so you’ve never entered Switzerland officially. The more interesting question: What if a Swiss resident flies an aircraft from the US to Botswana with a landing at LSZH and LSZA? For this, he must declare the aircraft at the customs booth in LSZH for temporary import. The Swiss ferry pilot can then fly the plane for 3 days without paying taxes through Switzerland and export it again at LSZA. Without paperwork, a temporary import into Switzerland is not possible. Same rules also apply when a Swiss resident wants to drive a EU-car inside Switzerland for several days. He needs to stop at the border and make a declaration of temporary import.
Pay VAT of one airplane in both EU and Switzerland and keep copies of the tax invoices in the airplane.
He pays the VAT twice over, literally? I can’t see many doing that.
you’re a resident of a country in two cases
That is clearly country dependent because the UK doesn’t do that, for example. The tax authority here does have vaguely similar rules in some scenarios e.g. when a foreign domiciled person is allowed back to the UK.
Thats not a problem when you don’t leave the airport, so you’ve never entered Switzerland officially.
What if he needs to sleep somewhere? 
This is amazing stuff Thanks for posting the detailed info.
Peter wrote:
He pays the VAT twice over, literally? I can’t see many doing that.Not a single person, but if multiple pilots with residences in both EU and Switzerland want to fly one same plane, a simple solution would be to pay taxes in both Switzerland and EU. This could come in handy for group ownerships and club airplanes close to the Swiss-EU border.
That is clearly country dependent because the UK doesn’t do that, for example. The tax authority here does have vaguely similar rules in some scenarios e.g. when a foreign domiciled person is allowed back to the UK.So what are the rules of residency in the UK exactly? In most European mainland countries, the rules are quite simple: You’re a resident in the country of your main address, and/or when you live there for more than 180-183 days per year.
What if he needs to sleep somewhere?I guess he can just go to the customs booth, declare his airplane for temporary import, and go off without paying anything as described for the above-mentioned scenario when the ferry pilot would make a stop in both LSZH and LSZA.
So what are the rules of residency in the UK exactly?
It depends on the purpose. For income tax, probably similar to yours. For domicile, something else.
Peter wrote:
For domicile
Can you elaborate what this is, as a residency purpose being different from tax (income or other)? For example, having an address in a country says nothing about residency…. it just means you either own property or know someone who agrees to receive mail or maintain some sort of accommodation or even just a post office box.
It is hugely complex. I know someone who used to be “foreign domiciled” and was paying a lot for accounting advice, and in the end it wasn’t worth it. A google on e.g.
uk foreign domicile history
digs out all you wanted to know, and more
There were “interesting developments” along the line e.g. the Swiss “banker” who stole the details of the bank’s UK account holders and sold the data to the UK HMRC (who are legally allowed to purchase stolen material, in order to collect taxes 
); this played a seminal role in a lot of people – legal and illegal – getting out of CH and the foreign domicile scene generally. I believe you can maintain the status if you give HMRC 30k a year, or some such…
If you earn money in the UK you need to declare it in the UK, the same for any money you earn in France needs to be declared in France. However if you reside more than 183 days, let’s say in France, you must declare all worldwide earnings in France. If there is a double taxation agreement you of course will only pay tax in one of the tax systems.
For instance a British person living in France, and in a State pension will pay tax on the state pension in France. However if that Brit receives eg a Civil Service pension, then they pay tax on that pension in the UK, although you should still declare it in France.
VAT is a totally different system. Generally the buyer pays the VAT to the seller at the point of sale. It is then for the seller to declare that VAT and pass it on to the appropriate authority in the country where the deal has taken place and under their VAT rules.
But let’s say you import an aircraft from outside the EU. If there is an EU tariff or customs charge on that aircraft you will need to pay that at the port of entry into the EU you will also need to pay VAT on that tariff or customs charge and that VAT is charged at the VAT rate chargeable by the country in which the port of entry is located.
I’ve just realised that this is almost like describing the laws of cricket:)
“Getting out of” resident-non domiciled" has nothing to do with Swiss data being sold to UK HMRC since under UK RND status foreign income and wealth is declared but not taxed unless remitted to the UK (therefore no point in avoiding making a declaration).
What has a lot to do with “getting out of” RND status is a change of legislation in 2017 changing the number of years before one becomes deemed domiciled, as well as applying automatic resident deemed domiciled status to people born in the UK, with the UK as domicile of origin and resident in the UK for 2017 to 2018, or later years.
gallois wrote:
If you earn money in the UK you need to declare it in the UK, the same for any money you earn in France needs to be declared in France.
I don’t know about the UK, but that’s not completely true for France. For example, if one earns revenue in France but has a residence for tax purposes in Switzerland, then the France revenue would normally be declared as such in Switzerland and taxed there. This is part of the tax treaty between France and Switzerland to avoid double-taxation. There is no need to make a tax declaration in France. Of course, if the revenue in France is from a French employer, then that employer needs to be informed otherwise they would normally deduct the tax at source. This is somewhat complicated since it also depends on how the revenue is “earned”. For example, if it requires significant physical presence in France then that is different than if all the revenue is “earned” remotely from Switzerland.
This can get quite complicated for companies with employees who live in one EU country and spend a lot of their work time in other EU countries, even if their entire paycheque comes from the company in their country of residence. This happens a lot with consulting work. Don’t ask how I know.
But that’s getting quite a ways off-topic.
Peter wrote:
That is clearly country dependent because the UK doesn’t do that, for example. The tax authority here does have vaguely similar rules in some scenarios e.g. when a foreign domiciled person is allowed back to the UK.
Sure it does. See https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-test-srt-rdr3#automatic-uk-tests
One is UK resident if one spends 183 days or more in the year in the UK.
