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