Canadaの税務居住ルール：183日テスト
183日のしきい値
Canadaにおける183日ルールの仕組み
Canada uses a combination of residential ties and the 183 day rule. Spending 183+ days in a calendar year creates a deemed residency.
暦年（1月〜12月）. これは、日数カウントが毎年1月1日にリセットされることを意味します。前年の日数は繰り越されません。
183日を超えると、Canadaは税務居住者としてあなたの全世界所得に課税する可能性があります。具体的な影響は、個人の状況、適用される租税条約、所得の種類によって異なります。
日数のカウント方法
Canada runs two residency tests in parallel. The factual residency test looks at the ties you maintain in Canada, sorting them into significant ones (a home, a spouse, dependants) and secondary ones (a driver licence, bank accounts, social and professional ties, provincial health coverage). Alongside that, the deemed residency rule treats anyone who spends 183 days or more in Canada in a calendar year as resident for the whole year, unless a tax treaty pulls them out.
1日とみなされる条件
Any calendar day with even partial presence in Canada counts toward the 183 day deemed residency total, including the day you arrive and the day you leave.
日数以外の判定基準
For most people, ties matter more than day count. Keeping a home in Canada, a Canadian spouse, or dependent children north of the border is the kind of significant tie that establishes residency on its own, even if you barely set foot in the country during the year.
特別税制
Canada has nothing comparable to the Spanish Beckham law or Portugal's NHR for incoming expats. New residents are taxed on their worldwide income from the day residency starts, and certain personal use property is deemed to have been acquired at that moment for capital gains purposes.
租税条約
Canadian treaties use the standard OECD tiebreaker, so even a deemed resident under the 183 day rule can be treated as non resident under a treaty if the OECD hierarchy points to the other country.
よくある質問
Can I be Canadian tax resident with fewer than 183 days?
Yes. The factual test cares about residential ties more than day count, so a home in Canada, a Canadian spouse, or dependants living in Canada will usually be enough on their own.
What happens at exactly 183 days?
At 183 you become a deemed resident of Canada for that calendar year and owe tax on your worldwide income for the year. If you also qualify as resident of another treaty country, the treaty tiebreaker can shift you back to non resident.
Does maintaining a Canadian bank account or driver licence trigger residency?
Not on its own. The CRA treats those as secondary ties, weighed alongside primary ones like a home, a spouse, or dependants. A long list of secondaries without any primaries can still tip you into residency, though.