Every residence test and treaty list on this page
- United States: US citizens and green-card holders are taxed on worldwide income wherever they live. 183 days or more this year meets the substantial presence test. 31+ days this year: you're resident if this year's days + a third of last year's + a sixth of the year before reach 183. Under 31 days this year: not resident by presence. https://www.irs.gov/individuals/international-taxpayers/determining-an-individuals-tax-residency-status
- France: More than 183 days in France makes France your main place of stay. Your home and family (your “foyer”) are in France. Your main work is in France — one criterion is enough. None of France's criteria met: no home and family, no main stay, no main work or economic centre in France. https://www.impots.gouv.fr
- United Kingdom: 183 days or more in the UK: automatically resident. Fewer than 16 days in the UK: automatically not resident. Full-time work in the UK can make you resident — the Statutory Residence Test decides. A home in the UK and none abroad can make you resident — the Statutory Residence Test decides. Neither automatic test applies: your UK ties (home, family, work, past years) and days decide. https://www.gov.uk/tax-foreign-income/residence
- Germany: A home in Germany (Wohnsitz) makes you resident. A usual stay of more than 6 months in Germany makes you resident. No home and no stay over 6 months in Germany. https://www.bundesfinanzministerium.de
- Spain: More than 183 days in Spain in the year. Your main business or economic interests are in Spain. Spain presumes you resident if your spouse and minor children live there — you can prove otherwise. Under 183 days and no economic centre in Spain. https://sede.agenciatributaria.gob.es
- Italy: 183 days or more of presence, registration or domicile in Italy. Your personal and family life (domicile) is in Italy. Under 183 days and no domicile in Italy. https://www.agenziaentrate.gov.it
- Portugal: More than 183 days in Portugal in 12 months. A home in Portugal kept as your usual residence can make you resident. Under 183 days and no usual residence in Portugal. https://info.portaldasfinancas.gov.pt
- Philippines: Philippine citizens living in the Philippines are taxed on worldwide income. Foreigners living in the Philippines are resident aliens — a stay over a year is presumed; over 180 days you're taxed at least on Philippine income as if doing business there. 180 days or fewer: taxed only on Philippine income. https://www.bir.gov.ph
- Thailand: 180 days or more in Thailand in the calendar year. Foreign income earned since 2024 is taxed when you bring it into Thailand (a proposed exemption for income brought in the same or next year is pending — check the Revenue Department). Under 180 days: taxed only on Thai income. https://www.rd.go.th
- Japan: Your home and work are in Japan: domiciled there. A year or more in Japan makes you resident. For your first 5 years in the last 10, foreign income is taxed only when paid in or brought into Japan. Coming to Japan for work expected to last a year or more usually counts as domicile from arrival. Short stay, no home or work in Japan. https://www.nta.go.jp/english/
- Singapore: 183 days or more in Singapore in the year. Foreign income you receive is generally tax-free for individuals. Under 183 days (stays straddling two years or three consecutive years can still count). https://www.iras.gov.sg
- Australia: You live and work in Australia: resident under the ‘resides’ test. 183 days or more in Australia and no usual home elsewhere. 183 days in Australia, but your usual home is elsewhere — the other tests decide. Short stay and no settled life in Australia. https://www.ato.gov.au
- Canada: Your home and family in Canada are significant residential ties. 183 days or more in Canada: deemed resident. No significant ties and under 183 days in Canada. https://www.canada.ca/en/revenue-agency.html
- New Zealand: More than 183 days in New Zealand in any 12 months. A permanent place of abode in New Zealand makes you resident. No home and under 183 days in New Zealand. https://www.ird.govt.nz
- United Arab Emirates: 183 days or more in the UAE (there's no personal income tax — residence helps you get a tax residence certificate). 90+ days with a home or job in the UAE can make you resident (no personal income tax). Short stay in the UAE. https://tax.gov.ae
- India: 182 days or more in India in the tax year. 60+ days: you may be resident if you also spent 365 days in India over the previous 4 years (other rules apply to Indian citizens). Under 60 days in India. https://www.incometax.gov.in
- Malaysia: 182 days or more in Malaysia. Foreign income received by resident individuals is exempt until the end of 2036. Under 182 days: linked stays across years can still make you resident. Short stay in Malaysia. https://www.hasil.gov.my
- Vietnam: 183 days or more in Vietnam. A registered permanent residence or long rental in Vietnam can make you resident. Under 183 days and no home in Vietnam. https://www.gdt.gov.vn
- Indonesia: More than 183 days in Indonesia in 12 months. Living and working in Indonesia with the intention to stay can make you resident. Short stay in Indonesia. https://www.pajak.go.id
- South Korea: 183 days or more in the year. Your home and family are there: domiciled. Under 183 days and no domicile. https://www.nts.go.kr
- China: 183 days or more in the year. Your home and family are there: domiciled. Under 183 days and no domicile. https://www.chinatax.gov.cn
- Brazil: More than 183 days in Brazil in 12 months. Under 183 days in Brazil. https://www.gov.br/receitafederal
- Hong Kong: Hong Kong taxes income from Hong Kong only — work done in Hong Kong is taxable whatever your residence. https://www.ird.gov.hk
The order: permanent home → centre of vital interests → habitual abode → nationality → agreement between the tax offices.
- Permanent home: you have one in only one country — that country wins.
- Centre of vital interests: your personal and economic ties are stronger in one country — it wins.
- Habitual abode: you spend more time in one country — it wins.
- Nationality: you're a citizen of only one of them — it wins.
- Nothing separates the two: the tax offices decide together (mutual agreement) — ask one of them to start it.
- Salary for work done where you live: taxed there.
- Salary for work done in the other country: that country can tax it (you're there 183+ days or paid by an employer from there); your residence country credits or exempts it.
- Short work trips to the other country: usually taxed only where you live, if you're there under 183 days and your employer isn't from there.
- Remote work done from where you live: taxed where you live, even if the employer is abroad.
- Days worked physically in the other country can be taxed there — keep a record of where you work each day.
- Rent: taxed first where the property is; your residence country taxes it too and gives a credit.
- Private pensions: usually taxed where you live. Government service pensions: usually taxed by the paying country.
- Dividends and interest: taxed where you live; the paying country may keep a capped withholding tax that you credit.
- Self-employed income: taxed where you live.
- Self-employed work in the other country: taxable there if you have a fixed base or permanent establishment there.
- United States: Armenia, Australia, Austria, Azerbaijan, Bangladesh, Barbados, Belarus, Belgium, Bulgaria, Canada, Chile, China, Cyprus, Czechia, Denmark, Egypt, Estonia, Finland, France, Georgia, Germany, Greece, Iceland, India, Indonesia, Ireland, Israel, Italy, Jamaica, Japan, Kazakhstan, South Korea, Kyrgyzstan, Latvia, Lithuania, Luxembourg, Malta, Mexico, Moldova, Morocco, Netherlands, New Zealand, Norway, Pakistan, Philippines, Poland, Portugal, Romania, Slovakia, Slovenia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Tajikistan, Thailand, Trinidad and Tobago, Tunisia, Türkiye, Turkmenistan, Ukraine, United Kingdom, Uzbekistan, Venezuela — https://www.irs.gov/businesses/international-businesses/united-states-income-tax-treaties-a-to-z
- Australia: Argentina, Austria, Belgium, Canada, Chile, China, Czechia, Denmark, Fiji, Finland, France, Germany, Hungary, Iceland, India, Indonesia, Ireland, Israel, Italy, Japan, Kiribati, South Korea, Malaysia, Malta, Mexico, Netherlands, New Zealand, Norway, Papua New Guinea, Philippines, Poland, Romania, Russia, Singapore, Slovakia, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Thailand, Türkiye, United Kingdom, United States, Vietnam — https://www.ato.gov.au/forms-and-instructions/foreign-income-tax-offset-rules-guide-2026/attachment-a-countries-and-jurisdictions-that-have-a-tax-treaty-with-australia
- Philippines: Australia, Austria, Bahrain, Bangladesh, Belgium, Brazil, Brunei, Canada, China, Czechia, Denmark, Finland, France, Germany, Hungary, India, Indonesia, Israel, Italy, Japan, South Korea, Kuwait, Malaysia, Mexico, Netherlands, New Zealand, Nigeria, Norway, Pakistan, Poland, Qatar, Romania, Russia, Singapore, Sri Lanka, Spain, Sweden, Switzerland, Thailand, Türkiye, United Arab Emirates, United Kingdom, United States, Vietnam — https://taxsummaries.pwc.com/philippines/individual/foreign-tax-relief-and-tax-treaties
- France: South Africa, Germany, Australia, Brazil, Canada, China, South Korea, Egypt, United Arab Emirates, Spain, United States, India, Indonesia, Ireland, Italy, Japan, Morocco, Mexico, New Zealand, Netherlands, Philippines, Portugal, United Kingdom, Singapore, Thailand, Türkiye, Vietnam, Greece, Malaysia, Hong Kong — https://bofip.impots.gouv.fr/node/7652
- United Kingdom: Australia, China, Egypt, Hong Kong, India, Indonesia, Japan, Kenya, Malaysia, Mexico, Morocco, Philippines, Portugal, France, Germany, United States, Spain, Italy, Ireland, Netherlands, Canada, New Zealand, Singapore, South Africa, Thailand, Türkiye, United Arab Emirates, Vietnam, Taiwan, South Korea, Greece — https://www.gov.uk/hmrc-internal-manuals/double-taxation-relief/dt15300
As a US citizen you also file a US return every year wherever you live. The foreign earned income exclusion ($132,900 for 2026) or the foreign tax credit usually prevents double tax; report foreign accounts over $10,000 (FBAR).