FlagSageTax residence
Glossary term
Tax residence is the status a country gives a person or company that lets it tax them as a resident, often on income from abroad as well as local income.
Each country sets its own tests. The United States applies a green card test and a substantial presence test to people who are not US citizens. The United Kingdom uses a statutory residence test that combines day counts, a home test, work tests and ties. Germany's Fiscal Code looks at whether a person keeps a dwelling there or has a habitual abode there.
Day counts are one test among several. A person can meet the tests of two countries in the same year, or of neither. Where two countries have a tax treaty, its tie-breaker rules may then decide which country counts as the residence country for that treaty.
Tax residence is a tax law status. A visa or residence permit does not decide it by itself, although some tests, such as the US green card test, look at immigration status. Leaving a country does not by itself end tax residence there. Check the current official guidance of each country involved.
Not to be confused with
- Domicile. Domicile is a separate legal concept about a person's long-term home, and some countries use it for different purposes than tax residence.
- Tax residency certificate. A certificate is a document that confirms residence for a stated purpose and period, not the test that creates it.
Sources
- Determining an individual's tax residency statusOfficial guidance
- RDR3: Statutory Residence Test (SRT) notesOfficial guidance
- Tax on foreign income: OverviewOfficial guidance
- The Fiscal Code of Germany (Abgabenordnung), English translationPrimary law
Related
- Countries covered
- General
- Sources
- 4 sources
- Tax year
- Current rules as checked
- Review
- Not professionally reviewed
Sources checked November 8, 2026