also called fiscal domicile
Your permanent home in the legal sense, the place you are deemed to belong to long term, which can persist even while you live abroad.
Domicile is the country the law treats as your true, permanent home, the place you fundamentally belong to, and it can cling to you even after years living elsewhere. That makes it stickier than residence, which is simply where you are living now. You can pack up and move, but shaking off a domicile takes deliberate steps, and until you do, that country may still tax your estate or your worldwide income.
You left your birth country a decade ago and think of yourself as long gone. But you kept a house there and never cut your ties cleanly, so for inheritance rules that country still counts as your domicile and reaches your assets when you die.
Some countries tax or apply inheritance rules based on domicile, which is stickier than residence and hard to shake off just by moving.
The difference is the whole point, so here is each one in a line.
These are the tie-breakers for when day counts are inconclusive or two countries both claim you.
A tie-breaker rule in a tax treaty decides which one wins, weighing your centre of vital interests, your habitual abode, and a substantial ties test of where your closest links are.
Domicile is your permanent home in the legal sense and deemed domicile is being treated as domiciled after long residence; the 183-day tie to home country is how your original country keeps claiming you until you settle elsewhere, and a tax treaty override is a clause letting a country tax you as if the treaty did not exist.
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