🇬🇧 United Kingdom vs 🇩🇪 Germany
Tax residency, treaties and PE risk compared.
| Dimension | 🇬🇧 United Kingdom | 🇩🇪 Germany |
|---|---|---|
| Residency rule | Statutory Residence Test (SRT) — ties + days | Wohnsitz (any home) OR 183 days |
| Day threshold | 183 days | 183 days |
| Warning band | from 90d | from 90d |
| Tax range | 20–45% | 14–45% + solidarity |
| Tax treaties | 130+ | 96+ |
| PE risk | Medium | High |
| Digital nomad visa | No | No |
| Best for | Returning expats using split-year treatment | Salaried EU employees who can't avoid German payroll |
| Common pitfall | Even 16 days can trigger residency if you have 4+ ties to the UK. | Keeping ANY accessible home in Germany = unlimited tax liability. No day-count escape. |
Verdict
For most nomads optimising for residency safety, 🇬🇧 United Kingdom is the lower-risk base versus 🇩🇪 Germany. Germany's high PE risk and 183-day rule make it easier to trip into full residency.
Deep dive
🇬🇧 United Kingdom residency rules →
Deep dive
🇩🇪 Germany residency rules →
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