🇪🇸 Spain vs 🇺🇸 United States
Tax residency, treaties and PE risk compared.
| Dimension | 🇪🇸 Spain | 🇺🇸 United States |
|---|---|---|
| Residency rule | 183-day rule + center of vital interests | Citizenship-based + Substantial Presence |
| Day threshold | 183 days | 183 days |
| Warning band | from 150d | from 122d |
| Tax range | 19–47% | 10–37% federal + state |
| Tax treaties | 95+ | 70+ |
| PE risk | High | High |
| Digital nomad visa | Yes | No |
| Best for | Beckham Law expats with employment income under €600k | US citizens optimising via FEIE ($126,500) and treaty benefits |
| Common pitfall | Spouse or kids living in Spain can trigger residency even at <183 days. | US citizens are taxed on worldwide income forever — there is no day-count exit. |
Verdict
Spain and United States carry similar residency risk on day-count alone — the deciding factor is usually treaty coverage (95 vs 70) and your specific income mix.
Deep dive
🇪🇸 Spain residency rules →
Deep dive
🇺🇸 United States residency rules →
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