In short
Tax residency decides which country may tax your worldwide income. It is separate from your residence permit: you can hold a permit and not be tax-resident, or become tax-resident without one. Most European countries use one or more tests — 183 days in a year or in any 12 months, a home available to you, the centre of your personal and economic life, or registration — and several (the Netherlands, France, Belgium) use no simple day count at all. If two countries both claim you, a tax treaty settles it in a fixed order: permanent home, centre of vital interests, habitual abode, nationality. Americans are a special case: the US taxes citizens and green-card holders wherever they live, so you file in both countries and use the foreign tax credit or the $132,900 earned income exclusion (2026) to avoid double tax, plus FBAR and Form 8938 for foreign accounts. The US has Social Security agreements with 22 of our 29 countries.
Tax residency: key facts
Last verified 28 September 2026| US citizenship-based tax | US citizens and green-card holders are taxed on worldwide income and keep filing US returns wherever they live — the US is the only country that does this in full (Eritrea charges a flat 2% on diaspora income)# Source: U.S. citizens and resident aliens abroad · Eritrea: diaspora tax (ecoi.net compilation, incl. UK Home Office and UN reporting) |
|---|---|
| Treaty tie-breaker | If two countries both treat you as resident, a tax treaty decides in this order: permanent home, centre of vital interests, habitual abode, nationality, then agreement between the two tax authorities# Source: OECD Council Recommendation OECD/LEGAL/0151 (Model Convention annex) · United States Model Income Tax Convention (2016) |
| Saving clause | US tax treaties let the US keep taxing its own citizens; with some exceptions — such as double-tax relief — they do not reduce US tax for Americans abroad# Source: United States Model Income Tax Convention (2016) · Tax treaties (IRS) |
| Foreign earned income exclusion | $132,900 of foreign earned income per person in 2026 (Form 2555); it does not cover dividends, interest, pensions or Social Security, and you cannot also claim a credit on the same income# Source: Rev. Proc. 2025-32 (section 4.39) · Foreign tax credit · Foreign earned income exclusion - what is foreign earned income |
| Foreign tax credit | Credit for income tax paid in Europe (Form 1116), with a 1-year carryback and 10-year carryforward; usually the better choice in countries that tax more than the US# Source: Foreign tax credit |
| FBAR | FinCEN Form 114 if your foreign accounts together exceed $10,000 at any time in the year; due 15 April, automatically extended to 15 October# Source: Report Foreign Bank and Financial Accounts · Comparison of Form 8938 and FBAR requirements |
| Form 8938 | For taxpayers living abroad: over $200,000 at year-end or $300,000 at any time (single); $400,000 / $600,000 married filing jointly# Source: Comparison of Form 8938 and FBAR requirements |
| European funds (PFIC) | Most non-US mutual funds and ETFs, including EU UCITS funds, are PFICs — reported on Form 8621 and taxed harshly unless you make an election# Source: Instructions for Form 8621 |
| US expatriation tax | There is no US exit tax for moving abroad; it applies only if you renounce citizenship or give up a green card held 8 of the last 15 years and have net worth of $2 million, average US income tax above $211,000 (2026), or cannot certify 5 years of compliance# Source: Expatriation tax · Instructions for Form 8854 · Rev. Proc. 2025-32 (section 4.39) |
| US state tax | Some states — California, Virginia, New Mexico, South Carolina and New York — keep treating you as resident unless you clearly give up your domicile there# Source: How to Change State Residency for Taxes (Bright!Tax) · FTB Publication 1031 (2025) Guidelines for Determining Resident Status |
| US Social Security agreements | In force with 22 of our 29 countries: Austria, Belgium, Czechia, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Luxembourg, Netherlands, Poland, Portugal, Romania (since 1 September 2026), Slovakia, Slovenia, Spain, Sweden, Switzerland and the UK# Source: U.S. International Social Security Agreements (status table) |
| No US Social Security agreement | Bulgaria, Croatia, Cyprus, Estonia, Latvia, Lithuania and Malta — Americans working there may owe contributions in both countries# Source: U.S. International Social Security Agreements (status table) |
| EU social security | You pay into one country's system at a time, normally where you work; since Regulation 1231/2010 this also covers non-EU nationals legally resident who move between EU countries (not Denmark); an A1 form keeps posted workers in their home system for up to 24 months# Source: Regulation (EU) No 1231/2010 (EUR-Lex) · Your Europe - Which country covers you |
Not American?
Canadians, Australians, Brits and other non-EU citizens: the same rules apply
The residency tests are the same for every newcomer. What differs for non-Americans:
- Canada
- Australia
- New Zealand
- United Kingdom
- Japan
- South Korea
- + other visa-free countries
| Canadians, Australians, Brits and others | Your home country normally stops taxing you once you are non-resident there — so the exit from home matters as much as the arrival in Europe. |
|---|---|
| US citizens and green-card holders | US citizens and green-card holders are taxed on worldwide income and keep filing US returns wherever they live — the US is the only country that does this in full (Eritrea charges a flat 2% on diaspora income). |
| Social security | US agreements cover 22 of our countries; other countries have their own agreements, and EU rules apply once you are legally resident in the EU. |
The Basics
What Tax Residency Means
Tax residency decides which country has the right to tax your worldwide income. Residents are usually taxed on everything they earn, wherever it comes from; non-residents only on income from that country. Each country sets its own rules, so you can be resident in two countries at once — or, briefly, in none.
Residence-based tax
You are taxed on worldwide income where you are resident, and only on local income elsewhere. Every country on this site uses this model.
Citizenship-based tax
US citizens and green-card holders are taxed on worldwide income and keep filing US returns wherever they live — the US is the only country that does this in full (Eritrea charges a flat 2% on diaspora income).
Visa ≠ tax residency
A residence permit gives you the right to live somewhere; tax residency follows where you actually live. Luxembourg, for example, states that a permit alone does not make you tax-resident.
How Countries Decide
The Common Residency Tests
| Test | How it works | Examples |
|---|---|---|
| Days present | Usually 183 days — in a calendar year, or in any 12 months | Czechia, Poland (calendar year); Portugal, Estonia, Latvia (any 12 months) |
| Longer stay | A continuous stay of more than 6 months | Germany, Austria, Luxembourg, Denmark, Finland, Sweden |
| Two-year count | Days in this year and last year combined | Ireland (280 days), Lithuania (280 days) |
| Home available to you | A home you keep for your own use, owned or rented | Germany, Austria, Czechia, Portugal |
| Centre of interests | Where your family, work and economic life are concentrated | Poland, Lithuania, Spain, France, Belgium |
| Registration | Being registered at an address or in the population register | Latvia (declared residence), Italy (register creates a presumption) |
| Facts and circumstances | No day count — all your ties are weighed together | Netherlands, UK (sufficient-ties test) |
| Very short stays | Residence after weeks, not months | Switzerland (30 days while working, 90 without); Cyprus (60-day rule) |
Simplified — the exact rule for each country is in the table below.
By Country
When You Become Tax-Resident in Each Country
| Country | Residency test |
|---|---|
| Austria | A home you keep available for your own use, or your habitual abode — a stay of more than 6 months makes you resident back to the first day |
| Belgium | Based on your home or centre of economic interests in Belgium, not a 183-day count |
| Bulgaria | Permanent address in Bulgaria, more than 183 days in any 12 months, or centre of vital interests there |
| Croatia | A home you own or hold, or a stay of at least 183 days, in one or two calendar years |
| Cyprus | More than 183 days a year, or the 60-day rule (with a home and work or business in Cyprus) |
| Czechia | A permanent home in Czechia, or at least 183 days there in a calendar year (every started day counts) |
| Denmark | Taking up residence — a home you actually move into — or a stay of more than 6 consecutive months; tax liability runs from the day you arrive |
| Estonia | Your place of residence is in Estonia, or you stay at least 183 days in any 12 months (part-days count); resident from the day you arrive |
| Finland | Your main home is in Finland, or you stay more than 6 months in a row (short trips abroad do not break it) |
| France | Based on your home, main place of stay, work or economic interests — not a simple 183-day count |
| Germany | A home available to you, or a stay of more than 6 months (even across a year-end) — then resident from day one; purely private stays of up to a year are excluded |
| Greece | More than 183 days in Greece in any 12-month period |
| Hungary | Your only permanent home or centre of interests in Hungary, or 183+ days a year if those tests are unclear |
| Ireland | 183 days or more in the calendar year, or 280 days over this year and last (years with 30 days or fewer do not count); any part of a day counts |
| Italy | For most of the year (183 days, counting part-days) your habitual abode, the centre of your personal and family life, or simply your physical presence is in Italy; registration in the population register is a presumption you can rebut (since 2024) |
| Latvia | Your declared place of residence is in Latvia, or you stay 183 days or more in any 12 months that begin or end in the tax year |
| Lithuania | Your permanent home or centre of interests is in Lithuania, or you stay 183 days in a calendar year, or 280 days over two years (with at least 90 in one of them) |
| Luxembourg | A home you actually use, or a stay of more than 6 consecutive months (it can span two tax years); a residence permit alone does not make you resident |
| Malta | More than 183 days in a year, or from arrival if you come to settle; people not domiciled in Malta are taxed on foreign income only when it is brought to Malta |
| Netherlands | No day count — it depends on where your permanent home is, judged on all the facts: family, work, insurance, doctor, children's school |
| Poland | Your centre of personal or economic interests is in Poland, or you spend more than 183 days there in the calendar year |
| Portugal | More than 183 days in any 12 months, or a home you appear to keep as your habitual residence on any day of that period; the year is split on arrival and departure |
| Romania | You become tax-resident if Romania is your home or centre of vital interests, or after more than 183 days in any 12 months |
| Slovakia | You are tax-resident if you have your home in Slovakia or spend at least 183 days there in a calendar year |
| Slovenia | You are tax-resident with a registered permanent residence, your habitual home or centre of interests in Slovenia, or more than 183 days there in a tax year |
| Spain | Tax-resident if you spend more than 183 days in Spain in a calendar year or have your main economic interests there |
| Sweden | You settle in Sweden or stay 6 months or more in a row; people who leave stay liable while they keep an essential connection such as a year-round home |
| Switzerland | You live there intending to stay, or you stay 30 days while working or 90 days without working (study and medical stays do not count) |
| United Kingdom | The Statutory Residence Test for each 6 April–5 April year: automatic overseas tests, then automatic UK tests (183 days, a UK home, full-time UK work), then a sufficient-ties test; split-year treatment in 8 cases |
Every rule comes from the country's national tax authority, cross-checked with PwC Worldwide Tax Summaries — open "Show sources" in the key facts or follow the country link.
Dual Residency
When Two Countries Both Claim You
It is easy to meet two countries' tests in the same year — for example 183 days in Portugal while keeping a home in Germany. Each country then taxes you as a resident, and the tax treaty between them decides which one wins. Without a treaty, double taxation is a real risk.
Permanent home
Where you have a home permanently available to you. If you have one in both countries, go to the next step.
Centre of vital interests
Where your personal and economic relations are closer — family, work, property, social life.
Habitual abode
Where you normally spend more time.
Nationality
The country of which you are a citizen.
Mutual agreement
The two tax authorities decide together.
US tax treaties let the US keep taxing its own citizens; with some exceptions — such as double-tax relief — they do not reduce US tax for Americans abroad. The tie-breaker can make you non-resident in the US for treaty purposes, but you still file a US return and must disclose the position on Form 8833.
To claim treaty relief in another country — for example a lower withholding rate on dividends — you need a tax residency certificate. Issued by your country's tax authority to prove residence under a treaty, so another country grants relief such as reduced withholding.
For Americans
What US Citizens Still Owe at Home
Becoming tax-resident in Europe does not end your US filing. You report worldwide income on your US return every year and use one of two tools to avoid paying twice on the same income.
| Item | What it means for you |
|---|---|
| Foreign tax credit | Credit for income tax paid in Europe (Form 1116), with a 1-year carryback and 10-year carryforward; usually the better choice in countries that tax more than the US |
| Foreign earned income exclusion | $132,900 of foreign earned income per person in 2026 (Form 2555); it does not cover dividends, interest, pensions or Social Security, and you cannot also claim a credit on the same income |
| FBAR | FinCEN Form 114 if your foreign accounts together exceed $10,000 at any time in the year; due 15 April, automatically extended to 15 October |
| Form 8938 | For taxpayers living abroad: over $200,000 at year-end or $300,000 at any time (single); $400,000 / $600,000 married filing jointly |
| European funds | Most non-US mutual funds and ETFs, including EU UCITS funds, are PFICs — reported on Form 8621 and taxed harshly unless you make an election |
| Companies, partnerships, trusts | Form 5471 for a foreign company you run or own 10%+ of, 8865 for foreign partnerships, 3520/3520-A for foreign trusts (many foreign pensions are exempt since 2020), 8833 for treaty-based positions |
| Your US state | Some states — California, Virginia, New Mexico, South Carolina and New York — keep treating you as resident unless you clearly give up your domicile there |
| Renouncing citizenship | There is no US exit tax for moving abroad; it applies only if you renounce citizenship or give up a green card held 8 of the last 15 years and have net worth of $2 million, average US income tax above $211,000 (2026), or cannot certify 5 years of compliance |
Sources: IRS, FinCEN and state tax authorities — see the key facts box for links.
A European fund that is a sensible choice for a local resident can be one of the worst-taxed investments for an American. Check PFIC treatment before you buy.
Common Mistakes
Where People Get Caught
Becoming resident by accident
A miscounted day total, a flat kept "just in case", or a partner and children who stay behind can make you resident — or keep you resident — without noticing.
Not leaving properly
Moving away does not always end residency. Sweden keeps taxing people who keep an essential connection such as a year-round home, and Finnish citizens stay resident for three years after leaving unless they show their ties have ended.
Exit taxes on shares
On leaving after 7 of the last 12 years as a resident, with 1% or more of a company (from 2025 also some fund holdings); paid in 7 instalments. On leaving after 6 of the last 10 years, with securities worth €800,000 or more or 50% of a company; deferred for moves within the EU. On leaving after 10 of the last 15 years, with shares or funds worth over €4 million (or a stake over 25% worth over €1 million); can be deferred for moves within the EU/EEA. Holders of 5% or more of a company get a protective assessment on the gain when they emigrate, payable when they sell or receive dividends.
Working remotely for a foreign employer
Under the OECD's 2025 guidance a home office is generally not a taxable presence of a foreign employer if you work there less than 50% of your time over 12 months; above that, only if there is a commercial reason. Payroll and social security obligations may also move with you.
Missing the reporting
EU banks report non-resident account holders to their home tax authorities every year (Common Reporting Standard); crypto platforms report too from 1 January 2026 (DAC8). Penalties for missed disclosures can be larger than the tax itself.
The year you arrive or leave
Some countries split the year (Portugal, Ireland for employment income, the UK in 8 cases); others, such as Italy, look at the whole year. Part-year returns are common.
Newcomer Regimes
Special Tax Regimes for New Residents
Many countries offer lower tax to people who were not resident before. They have strict conditions and deadlines — and for Americans the saving is often smaller, because the US taxes the difference.
| Country | Regime |
|---|---|
| Spain | 24% on employment income up to €600,000 (47% above) for the year of arrival plus 5 years, if you were not resident in the previous 5 years and move for a job, remote work (incl. the digital nomad visa), a directorship or an innovative business — not for non-lucrative visa holders. Optional: file Modelo 149 within 6 months of starting work |
| Portugal | 20% flat tax for 10 years on income from qualifying highly skilled jobs, research and startups, with most foreign income exempt — not pensions; you must not have lived in Portugal in the previous 5 years |
| Italy | €300,000 a year on all foreign income (€50,000 per family member) for people moving from 2026; €200,000 for moves from 10 August 2024 to 2025. 50% of work income tax-free for 5 years (60% with a minor child), up to €600,000; you must have lived abroad 3 years and be highly qualified. 7% on all foreign income for 10 years if you receive a foreign pension and move to a southern town of up to 30,000 people (since April 2026); no Italian tax on foreign assets |
| Greece | If you receive a foreign pension, all your foreign income can be taxed at a flat 7% for up to 15 years; not tax resident in Greece in 5 of the previous 6 years; apply by 31 March |
| Netherlands | 30% of salary tax-free for up to 5 years for employees recruited from abroad earning over €48,013 taxable (€36,497 under 30 with a master's) in 2026; 27% from 2027 |
| Sweden | 25% of pay free of income tax and social charges for up to 7 years for foreign experts earning more than SEK 88,800 a month (2026) who were not tax resident in Sweden in the previous 5 years; apply within 3 months of starting work |
| Finland | 25% flat tax from 2026 for up to 84 months; salary at least €5,800 a month; no Finnish tax residence in the past 5 years; apply within 90 days |
| Denmark | 32.84% (27% + 8% labour-market contribution) for up to 7 years; pay at least DKK 65,400 a month (2026); no Danish tax liability in the past 10 years |
| Luxembourg | 50% of salary tax-free (counted on pay up to €400,000) for 8 years, for newcomers paid at least €75,000 (since 2025) |
| France | Tax relief for people recruited from abroad, until the end of the 8th year |
| Cyprus | Non-domiciled residents pay no defence contribution on dividends and interest for up to 17 of 20 years; from 2026 an optional €250,000 per 5 years extends it |
| Malta | Foreign income is taxed only if brought to Malta; a €5,000 minimum tax applies if foreign income is €35,000 or more |
| Ireland | Residents not domiciled in Ireland pay tax on foreign income only when it is brought into Ireland — but Irish employment income is always taxed |
| United Kingdom | Since 6 April 2025 the UK taxes residents on worldwide income (no remittance basis); people arriving after 10 years abroad can claim 100% relief on foreign income and gains for their first 4 years |
| Switzerland | Foreign nationals moving to Switzerland who do not work there can be taxed on their spending: federal minimum base CHF 435,000 (2026) and at least 7× the rent; not available in Zurich, Basel-Stadt, Basel-Landschaft, Schaffhausen or Appenzell Ausserrhoden |
Conditions change often — check the country guide and apply before the deadline; many regimes are lost by applying late.
Checklist
Tax Residency Checklist for Your Move
Before you move
- Learn the residency tests of the country you leave and the one you move to.
- Check whether a tax treaty exists and read its tie-breaker article.
- List every income type and where it comes from — salary, business, investments, rent, pensions, crypto.
- Check exit tax on shares, company holdings and funds.
- Check a newcomer regime's conditions and deadline before you arrive.
- Confirm which country's social security you will pay into.
When you leave
- Deregister where required and tell your bank, employer and pension provider your new address.
- Sell your home or let it long-term, so it is no longer available to you.
- If you are American, make sure your US state no longer treats you as resident.
When you arrive
- Register your address and get your tax number.
- Register for social security and health insurance.
- Sign a long-term lease or buy a home, and open a local bank account.
- Apply for any newcomer regime before its deadline.
- Request a tax residency certificate once you qualify.
Every year
- Keep a day count for every country, backed by tickets and card records.
- Keep your home, family and work in one country.
- Claim treaty relief and foreign tax credits on your returns — they are not automatic.
- File on time in every country where you must file, even if you owe nothing.
- Keep your records for at least 5–10 years.
Americans, also
- File your US return every year and choose the foreign tax credit or the exclusion.
- File the FBAR and Form 8938 when you pass the thresholds.
- Check PFIC rules before buying any European fund.
This page explains the rules; it is not tax advice. We don't give tax advice ourselves, and we don't guarantee a visa — the authority decides. When your plan needs it, we bring in licensed lawyers and cross-border accountants, and we recommend a review before you move and after your first year, because mistakes in the year you arrive or leave are the hardest to fix.
FAQ
Frequently asked questions
Does a residence permit make me tax-resident?
Not by itself. Tax residency depends on the country's tests — days, home, centre of interests or registration. You can hold a permit without being tax-resident, or become tax-resident without one.
Is 183 days the rule everywhere in Europe?
No. Many countries use 183 days, but some count any 12 months, some look at a 6-month stay, Ireland and Lithuania also count 280 days over two years, and the Netherlands, France and Belgium look at your home and ties instead of a day count. Switzerland can make you resident after 30 days of work.
Do Americans living in Europe still pay US tax?
You still file a US return every year. In most of Western Europe local tax is higher than US tax, so the foreign tax credit often leaves little or no US tax to pay, but the filing and the FBAR still apply.
What happens if two countries both say I am resident?
The tax treaty between them decides — permanent home first, then centre of vital interests, habitual abode and nationality. Without a treaty you may be taxed twice and rely on each country's own relief.
Do I pay Social Security in the US and in Europe?
Not in the 22 countries on our site that have an agreement with the US — you pay into one system. In Bulgaria, Croatia, Cyprus, Estonia, Latvia, Lithuania and Malta there is no agreement, so double contributions are possible.
Across Europe
Compare all 29 countries by topic
Planning Your Move Around Tax?
Tell us where you live now and where you want to go — we'll explain the residency rules on both sides and the order of steps. The first consultation is free.
Social Security
Social Security Is a Separate Question
Where you pay social contributions is decided separately from where you pay income tax — and the answer can be a different country.
US agreements
In force with 22 of our 29 countries: Austria, Belgium, Czechia, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Luxembourg, Netherlands, Poland, Portugal, Romania (since 1 September 2026), Slovakia, Slovenia, Spain, Sweden, Switzerland and the UK. Under an agreement, workers sent abroad for 5 years or less stay in the US system with a certificate of coverage from the SSA.
No agreement
Bulgaria, Croatia, Cyprus, Estonia, Latvia, Lithuania and Malta — Americans working there may owe contributions in both countries.
Moving within the EU later
You pay into one country's system at a time, normally where you work; since Regulation 1231/2010 this also covers non-EU nationals legally resident who move between EU countries (not Denmark); an A1 form keeps posted workers in their home system for up to 24 months.