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