🇺🇸 United States vs 🇩🇪 Germany

Tax residency, treaties and PE risk compared.

Dimension🇺🇸 United States🇩🇪 Germany
Residency ruleCitizenship-based + Substantial PresenceWohnsitz (any home) OR 183 days
Day threshold183 days183 days
Warning bandfrom 122dfrom 90d
Tax range10–37% federal + state14–45% + solidarity
Tax treaties70+96+
PE riskHighHigh
Digital nomad visaNoNo
Best forUS citizens optimising via FEIE ($126,500) and treaty benefitsSalaried EU employees who can't avoid German payroll
Common pitfallUS citizens are taxed on worldwide income forever — there is no day-count exit.Keeping ANY accessible home in Germany = unlimited tax liability. No day-count escape.

Verdict

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

Deep dive

🇺🇸 United States residency rules →

Deep dive

🇩🇪 Germany residency rules →

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