The case
Lawful, not evasion
Tax avoidance is permitted. The line runs at the truthfulness of what you declare — not at the size of what you save.
Genuinely at zero
Someone with unlimited tax liability in no state pays no income tax on income that has no territorial connecting factor. Carried out in full, that holds.
Sound for banking and for treaties
The robust variant — a real address, a tax number, a certificate of residence — keeps the account and treaty protection. Not a half-departure that topples later.
Residence is triggered differently in every state. Choose yours.
Your country of residence is already detected below — from your device’s time zone and language setting, with no IP lookup and no request to any third party. Choose any other jurisdiction and the card beneath rewrites itself: what triggers residence, what part the 183 days really play, whether an exit tax bites, and what trails on after departure.
This overview stands without JavaScript and in every printed copy. With JavaScript enabled, the selectable country card with fully written-out notes takes its place.
| State | Residence attaches to | Exit taxation | Trailing liability |
|---|---|---|---|
| AT · Austria | Dwelling, Day count | Wegzugsbesteuerung — exit tax (§ 27 EStG) | — |
| BE · Belgium | Dwelling, Centre of life | — | — |
| BG · Bulgaria | Dwelling, Day count, Centre of life | — | — |
| HR · Croatia | Dwelling, Day count, Centre of life | — | — |
| CY · Cyprus | Dwelling, Day count | Exit charge on certain holdings | — |
| CZ · Czechia | Dwelling, Day count, Centre of life | — | — |
| DK · Denmark | Dwelling, Day count | Fraflytterskat — exit tax on shares | — |
| EE · Estonia | Dwelling, Day count, Population register | — | — |
| FI · Finland | Dwelling, Day count, Centre of life | — | 3-year rule after departure |
| FR · France | Dwelling, Centre of life, Day count | Exit tax (art. 167 bis CGI) | — |
| DE · Germany | Dwelling, Day count | Wegzugsbesteuerung — exit tax (§ 6 AStG) | Extended limited tax liability (§ 2 AStG) |
| EL · Greece | Dwelling, Day count, Centre of life | — | — |
| HU · Hungary | Dwelling, Day count, Centre of life | — | — |
| IE · Ireland | Dwelling, Day count | — | Ordinary residence trails 3 years |
| IT · Italy | Dwelling, Population register, Centre of life | — | Presumption on move to a listed state |
| LV · Latvia | Dwelling, Day count, Population register | — | — |
| LT · Lithuania | Dwelling, Day count, Centre of life | — | — |
| LU · Luxembourg | Dwelling, Day count | — | — |
| MT · Malta | Dwelling, Day count | — | — |
| NL · Netherlands | All circumstances | — | Inheritance-tax fiction, 10 years (art. 3 SW) |
| PL · Poland | Day count, Centre of life | — | — |
| PT · Portugal | Dwelling, Day count | — | — |
| RO · Romania | Dwelling, Day count, Centre of life | — | Trailing liability up to 3 years |
| SK · Slovakia | Dwelling, Day count | — | — |
| SI · Slovenia | Dwelling, Day count, Centre of life | — | — |
| ES · Spain | Day count, Centre of life | Exit tax (art. 95 bis LIRPF) | Presumption on move to a listed state |
| SE · Sweden | Dwelling, Day count | — | Väsentlig anknytning — up to 10 years |
| IS · Iceland | Dwelling, Day count | — | — |
| LI · Liechtenstein | Dwelling, Day count | — | — |
| NO · Norway | Dwelling, Day count | Utflyttingsskatt on latent gains | — |
01What the rule actually is
The 183-day rule is not a worldwide exemption. It is two things: a national residence test in some states — and a tie-breaker in double taxation treaties, deciding which of two states may tax. Whether there is any tax at all is decided by residence — and that is exactly where the lever sits.
Some states tie their own residence to a length of stay. That test answers the question of that one state and no other — about the rest it says nothing.
Where two states both have a claim, the treaty assigns the taxing right to one of them. The tie-breaker presupposes that you are resident somewhere. Whoever is resident nowhere has no use for it — and forgoes the treaty benefits along with it (see below).
02The trap first
Counting days measures the wrong thing. The three legal systems on this page work differently — two of them may not count days at all. Knowing that before the first step means building correctly from the outset.
Germany and Austria count no days at all where a dwelling exists.
Unlimited tax liability attaches to a domicile — to a dwelling you can dispose of. A room at your parents', a tenancy kept on, a key: any of these suffices. The 183 days are then irrelevant.
The Netherlands counts no days whatever.
Art. 4 AWR decides “naar de omstandigheden” — on the circumstances taken as a whole: family, dwelling, bank, doctor, memberships. There is no period anyone can simply wait out.
Both mean only this: Going halfway is not enough. Giving the dwelling up in earnest — no power of disposal, no key — removes the connecting factor from § 8 AO and § 26 BAO; leaving the Netherlands means moving the circumstances as a whole. That is precisely what the next section consists of.
03What actually works
The concept holds — if it is carried out fully rather than halfway. Here is the part that stands.
Anyone who holds a domicile nowhere and reaches the national residence thresholds nowhere is nowhere subject to unlimited tax liability.
Unlimited tax liability attaches to domicile or residence (§ 8 AO, § 26 BAO, Art. 4 AWR). If both fall away everywhere — no dwelling at your disposal, and under 183 days in most places — it ends everywhere. Income with no territorial connecting factor then bears no income tax. That is the true core of the PT concept.
That holds — without qualification. For the burden actually to arrive at zero, cut the last connecting factors at the same time; they are known and therefore plannable: retain no domestic sources (§ 49 EStG), let § 2 AStG run empty through your choice of destination or by cutting substantial domestic interests, and anchor the place of management with real substance in the new location (§ 10 AO). What the state of being “resident nowhere” otherwise requires — an account, treaty protection — is set out under Doing it cleanly.
Territorial and lump-sum tax systems
They exist and may lawfully be used: the UAE, Paraguay, Panama, Georgia, Malaysia, Uruguay — together with non-dom regimes in several jurisdictions.
Tax avoidance is lawful
The line to evasion is not blurred. It runs at the truthfulness of what you declare — not at the size of what you save.
Two constructions hold: genuinely resident nowhere — or genuinely resident somewhere favourable. What does not hold is the half-measure.
The pure variant demands completeness — no dwelling, no threshold, no residual connection — and then it holds. The robust variant takes a real address, a tax number and a certificate of residence in a favourable state, and is thereby sound for banking and for treaties. “PT” as it is marketed does not fail on the concept but on half-execution; “a cleanly executed departure” is the substance underneath — and that works.
04Doing it cleanly
None of the following points is a prohibition. Each is a task whose solution is settled before departure — the most important one first.
Deregistering is not deregistering for tax.
Deregistering at the residents' registration office while keeping the dwelling does not end tax liability. Declaring otherwise to the tax office is tax evasion under § 370 AO — a criminal offence, not a regulatory one. The line is sharp, and that is exactly what makes it plannable: give the dwelling up entirely, end your power of disposal — and the deregistration is then true for tax as well.
§ 27 öEStG
Exit taxation
Taxes unrealised gains in corporate shareholdings — triggered by the departure itself, not by a sale. Timing and sequence can be arranged — and are settled before departure, not after.
Extended limited tax liability
For ten years, for former Germans who move to a low-tax country and retain substantial economic interests in Germany. Both must coincide — and both are in your hands.
Domestic income remains taxable
Real property and certain business income: German sources remain taxable in Germany — wherever you live. Anyone who retains none has nothing to tax here.
§§ 7–14 AStG
The place of management follows the manager
Running your company from wherever you happen to be sitting creates a permanent establishment there, or moves the company's residence. This is where most half-built structures fail. The solution is the same as everywhere on this page: real substance — management where the company is meant to be resident.
Banks require a residence
A self-certification of tax residence with a TIN is standard. “Resident nowhere” is increasingly unbankable — and without a certificate of residence there are no treaty benefits: full withholding tax on dividends and interest. With a genuine residence and a certificate, both are solved — the account and treaty protection alike; the pure variant prices the withholding tax in deliberately. The burden of proof lies on whoever asserts that residence has ended: deregistration, actual surrender of the dwelling, evidence of travel and stays, and where applicable a certificate of residence. Once the dwelling is given up, it is domicile that decides in DE/AT — not the day count; unlimited tax liability ends when domicile and residence fall away, not on a calendar date.
No statutory safety net any longer
No statutory health insurance, and no further pension accrual. International private cover is a real, recurring cost — not a footnote, but priced in from the start, not an obstacle either.
Giving up EU citizenship makes Perpetual Traveling harder in Europe, not easier: as a third-country national you fall under the 90/180 rule in the Schengen area. Outside Europe that restriction falls away.
The two concepts therefore complement one another on one condition only — that the centre of life is meant to lie outside the EU in any case.
← Back to the main page · End EU-CitizenshipThe sequence is settled before departure — not after.
The order of departure, renunciation and share transfers determines the exit tax — and it cannot be changed retroactively. This page therefore calculates nothing: individual figures depend on the individual case. Questions or comments? inquiries@kgd-embassy.org
This website offers general legal information and not legal advice within the meaning of § 2 RDG. It does not replace an individual assessment by a qualified lawyer. No warranty is given as to completeness or currency.