🇩🇪 Germany vs 🇺🇸 United States
Tax residency, treaties and PE risk compared.
| Dimension | 🇩🇪 Germany | 🇺🇸 United States |
|---|---|---|
| Residency rule | Wohnsitz (any home) OR 183 days | Citizenship-based + Substantial Presence |
| Day threshold | 183 days | 183 days |
| Warning band | from 90d | from 122d |
| Tax range | 14–45% + solidarity | 10–37% federal + state |
| Tax treaties | 96+ | 70+ |
| PE risk | High | High |
| Digital nomad visa | No | No |
| Best for | Salaried EU employees who can't avoid German payroll | US citizens optimising via FEIE ($126,500) and treaty benefits |
| Common pitfall | Keeping 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
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