🇬🇧 United Kingdom vs 🇺🇸 United States

Tax residency, treaties and PE risk compared.

Dimension🇬🇧 United Kingdom🇺🇸 United States
Residency ruleStatutory Residence Test (SRT) — ties + daysCitizenship-based + Substantial Presence
Day threshold183 days183 days
Warning bandfrom 90dfrom 122d
Tax range20–45%10–37% federal + state
Tax treaties130+70+
PE riskMediumHigh
Digital nomad visaNoNo
Best forReturning expats using split-year treatmentUS citizens optimising via FEIE ($126,500) and treaty benefits
Common pitfallEven 16 days can trigger residency if you have 4+ ties to the UK.US citizens are taxed on worldwide income forever — there is no day-count exit.

Verdict

For most nomads optimising for residency safety, 🇬🇧 United Kingdom is the lower-risk base versus 🇺🇸 United States. United States's high PE risk and 183-day rule make it easier to trip into full residency.

Deep dive

🇬🇧 United Kingdom residency rules →

Deep dive

🇺🇸 United States residency rules →

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