🇩🇪 Germany vs 🇺🇸 United States

Tax residency, treaties and PE risk compared.

Dimension🇩🇪 Germany🇺🇸 United States
Residency ruleWohnsitz (any home) OR 183 daysCitizenship-based + Substantial Presence
Day threshold183 days183 days
Warning bandfrom 90dfrom 122d
Tax range14–45% + solidarity10–37% federal + state
Tax treaties96+70+
PE riskHighHigh
Digital nomad visaNoNo
Best forSalaried EU employees who can't avoid German payrollUS citizens optimising via FEIE ($126,500) and treaty benefits
Common pitfallKeeping ANY accessible home in Germany = unlimited tax liability. No day-count escape.US citizens are taxed on worldwide income forever — there is no day-count exit.

Verdict

Germany and United States carry similar residency risk on day-count alone — the deciding factor is usually treaty coverage (96 vs 70) and your specific income mix.

Deep dive

🇩🇪 Germany residency rules →

Deep dive

🇺🇸 United States residency rules →

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