Tax residence in Germany for Singapore taxpayers

Germany treats you as tax resident if you keep a home there that you can use (Wohnsitz) or stay more than six months in a row — even across two calendar years. Singapore decides your status for the calendar year by 183 days of presence or employment, normal residence of a citizen or PR, or IRAS's two- and three-year rules. If both countries treat you as resident, Art. 4(2) of the Singapore–Germany Agreement of 2004 (as amended in 2019) decides.

Check your status: Singapore and Germany

Free, no sign-up, about 3 minutes. Conclusion under Singapore's Income Tax Act 1947, compared with the law of Germany and the tax treaty (DTA).

When Germany treats you as a tax resident

In Germany the dwelling itself is decisive: if you keep a flat or room that you can use at any time, you are resident — regardless of days spent and of where your centre of vital interests is.

The German six months are counted continuously and are not tied to the calendar year: a stay from October to April already creates a habitual abode.

You have a home in Germany — under § 8 AO this is a Wohnsitz (domicile), so under German law you are resident with unlimited tax liability, even if your centre of vital interests is in Singapore.
You stayed in Germany continuously for more than six months for a purpose other than a visit or holiday — under § 9 AO this is a habitual abode from the first day, and you are resident in Germany.

When you are a non-resident

Your stay was only a visit, holiday or medical treatment of up to one year and you have no home in Germany — no habitual abode arises; you are not resident in Germany.
You have no home in Germany and your uninterrupted stay did not exceed six months — you are not resident in Germany. German-source income (in particular wages for work physically performed in Germany) is still subject to limited tax liability there.

Where the rules of Germany clash with Singapore tax rules

Collision: a German home makes you German-resident, Singapore counts days and normal residence. For Germany a dwelling you can use at any time (Wohnsitz) is enough: you are resident with worldwide tax liability even if your centre of vital interests is in Singapore (BFH, I R 74/16), and no minimum number of days is required (BFH, I R 58/16). Singapore decides residence for the calendar year: 183 days or more of presence or employment in Singapore, normal residence in Singapore as a citizen or Permanent Resident, or IRAS's administrative two- and three-year rules for foreigners (s. 2(1) Income Tax Act 1947). Keeping your flat in Germany while you live or work in Singapore can therefore make you resident in both countries. Article 4(2) of the Singapore–Germany Agreement decides: permanent home → centre of vital interests → habitual abode (also where you have a permanent home in neither State) → nationality → mutual agreement. Keep evidence for each step (lease, where your family lives, employment, days).
Collision: six continuous months in Germany vs. Singapore's calendar-year count. Germany counts six months of uninterrupted presence regardless of calendar-year boundaries, and residence then applies from the first day (§ 9 AO). A stay from October to April makes you German-resident although you spent fewer than 183 days in Germany in each calendar year. Singapore decides each calendar year as a whole (the basis period for the following Year of Assessment): with 183 days in Singapore in one of those years, as a citizen or PR who normally lives in Singapore, or under IRAS's two- or three-year rules you remain a Singapore resident for that year. For part of such a stay you may be resident in both countries; the tie-breaker in Art. 4(2) of the Agreement decides.

What else to know

How Singapore relieves double taxation of income from Germany. If Singapore is your state of residence, Germany may still tax German-source income as the Agreement allows — e.g. pay for work in Germany beyond the limits of Art. 15(2), or rent from German property. Singapore credits the German tax against Singapore tax on that income (Art. 24(2)(a)), and German income received in Singapore is exempt where the conditions of s. 13(7A), 13(8) or 13(12) of the Income Tax Act are met (Art. 24(2)(b)). As foreign-sourced income received by a resident individual is generally exempt in Singapore anyway, the German tax usually stays as the final tax. The Agreement also has a remittance clause: if Germany reduces its tax on income that Singapore taxes only when remitted to or received in Singapore, the reduction applies only to the amount remitted or received (Art. 22) — not where Singapore exempts the income under Art. 24(2)(b).
Working in Germany while not German-resident: 183 days in any twelve months. Even as a non-resident of Germany you owe German tax on wages for work physically performed in Germany (§ 49(1) no. 4(a) EStG), unless all conditions of Art. 15(2) of the Singapore–Germany Agreement are met: no more than 183 days in Germany in any twelve-month period commencing or ending in the calendar year concerned, an employer that is not resident in Germany, pay not borne by a permanent establishment or fixed base in Germany — and the pay is subject to tax in the State of residence. Singapore taxes pay for work done abroad only in limited cases (for example overseas work incidental to a Singapore employment), so whether this last condition is met depends on your facts. If a German group company bears your salary, the exemption does not apply from the first day.
Year of moving: Germany splits the year, Singapore does not. In the year you arrive in or leave Germany, Germany taxes worldwide income only for the period of unlimited liability, and foreign income for the rest of the year raises the rate (§ 32b EStG). Singapore sets your status for the whole calendar year and taxes that year's income in the following Year of Assessment (income of 2026 — YA 2027): in the year of the move you are either resident or non-resident in Singapore for the entire year. Both countries use the calendar year, but Singapore notices and certificates show a YA one year later — match the periods in both returns.
Moving from Germany to Singapore: exit taxation and Art. 13(7). If you move from Germany to Singapore and in the last five years held at least 1% of a corporation, Germany taxes the increase in value of the shares as if you had sold them (§ 6 AStG). Under the Agreement gains from selling other shares are generally taxable only in the State of residence (Art. 13(6)); but if you were resident in Germany for at least five years, Germany may tax the gain on shares in German companies for the period of your German residence (Art. 13(7)). Singapore has no exit tax and generally does not tax capital gains of individuals unless the sale amounts to trading.
Pensions: private pensions in the State of residence, statutory pensions in the paying State. Pensions and annuities paid from the other State are taxable only in your State of residence (Art. 18(1)). Benefits from the German or Singapore statutory social insurance are taxable only in the paying State (Art. 18(2)): a German statutory pension therefore stays taxable only in Germany after you move to Singapore. Since the 2019 Protocol, withdrawals from the Singapore Supplementary Retirement Scheme (SRS) by a resident of Germany are taxable only in Singapore, and German pensions based on contributions that were tax-relieved in Germany for more than five years are taxable only in Germany (Art. 18(4)). Government pensions are taxable in the paying State unless you are a resident and a national of the other State (Art. 19(2)).
Students and trainees from Singapore in Germany. Under Art. 20(2) of the Singapore–Germany Agreement, a student or business apprentice from Singapore who is in Germany solely for education or training is not taxed in Germany on payments from sources outside Germany for maintenance, education or training; Art. 20(1) has a separate rule for visiting professors and teachers staying up to two years. A continuous stay of more than six months still makes a student German-resident under § 9 AO.
Social security: no Germany–Singapore agreement. Germany has no social security agreement with Singapore; Singapore is not on the Deutsche Rentenversicherung list. Insurance periods in the two countries are not added together, and during a secondment you may be liable to contribute in both countries. The tax treaty does not cover social security contributions — clarify your insurance position with your employer and the Deutsche Rentenversicherung before a posting.
Treaty residence in Germany: a German certificate of residence for Singapore payers. If the Agreement makes Germany your State of residence, give Singapore payers a certificate of residence from your Finanzamt so that they can apply the treaty rates or exemptions; IRAS requires the payer to obtain the certificate of the non-resident payee. Keep Singapore tax documents on income and tax paid for the exemption or credit in your German return.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Agreement between the Republic of Singapore and the Federal Republic of Germany for the avoidance of double taxation with respect to taxes on income and on capital (signed at Singapore on 28 June 2004), with Protocol, as amended by the Protocol of 9 December 2019. The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

The treaty in detail: income, rates, the 183-day rule →

Terms you will come across in Germany

Wohnsitz: domicile — a home you keep and can use at any time
gewöhnlicher Aufenthalt: habitual abode — more than six months of continuous stay
unbeschränkte Steuerpflicht: unlimited tax liability on worldwide income (resident)
beschränkte Steuerpflicht: tax only on German-source income (non-resident)
Progressionsvorbehalt: exempt income still raises the tax rate on other income
Finanzamt: local tax office, which also issues certificates of residence

Questions

Which treaty applies between Singapore and Germany?

The Agreement signed at Singapore on 28 June 2004, in force since 12 December 2006, as amended by the Protocol of 9 December 2019 (applying from 2022). Art. 4(2) resolves dual residence: permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement.

How many days can I work in Germany before Germany taxes my salary?

Under Art. 15(2) Germany cannot tax it if you are there no more than 183 days in any twelve-month period starting or ending in the calendar year, the employer is not German-resident, no German permanent establishment bears the pay — and the pay is subject to tax in your State of residence. A German home or more than six months' stay makes you German-resident anyway.

Does Singapore tax my German income?

Generally not: foreign-sourced income received in Singapore by a resident individual is exempt (s. 13(7A)). Otherwise Singapore credits the German tax (Art. 24(2)). If Germany reduces its tax on income Singapore taxes only when remitted, the reduction covers only the remitted amount (Art. 22).

Sources

Legislation and official guidance

§ 1(1) EStG — Individuals with a domicile (Wohnsitz) or habitual abode (gewöhnlicher Aufenthalt) in Germany have unlimited tax liability, i.e. they are taxed on worldwide income.
§ 8 AO — A person has a domicile (Wohnsitz) where they keep a dwelling under circumstances indicating that they will retain and use it.
§ 9 AO — Habitual abode means presence that is not merely temporary. An uninterrupted stay of more than six months is always a habitual abode, from the first day; short interruptions are disregarded. Exception: stays solely for visits, recreation, medical treatment or similar private purposes lasting no longer than one year.
§ 9 sentence 3 AO — The six-month rule does not apply if the stay is solely for a visit, recreation, medical treatment or a similar private purpose and does not exceed one year.
§ 1(3)–(4) EStG — Without a domicile or habitual abode, liability is limited to German-source income (§ 49). On application, a non-resident can be treated as having unlimited liability if at least 90 % of their income is subject to German tax.
§ 49(1) no. 4(a) EStG — Employment income is German-source income if the work is performed or used (verwertet) in Germany.
s. 2(1) Income Tax Act 1947 (definition of «resident in Singapore», para (a)) — An individual is resident in Singapore if, in the year preceding the year of assessment, he or she resides in Singapore except for such temporary absences as may be reasonable and not inconsistent with a claim to be resident; also resident is a person who in that year was physically present or exercised employment in Singapore (other than as a company director) for 183 days or more.
IRAS — «Working out my tax residency» (updated 12 May 2026) — A Singapore citizen or permanent resident who normally resides in Singapore, except for temporary absences, is a tax resident. A foreigner is resident for a year of assessment if, in the preceding calendar year, he or she stayed or worked in Singapore for at least 183 days, or stays or works in Singapore continuously for three consecutive years (then for all three years, even with fewer than 183 days in the first and third). A foreign employee whose employment spans two calendar years is resident for both years if the period of employment, together with the stay immediately before and after it, is a continuous period of at least 183 days (not for company directors, public entertainers and professionals). Days include weekends and public holidays, and temporary absences (leave abroad, business trips) connected with the employment in Singapore.
Art. 4(2) Singapore–Germany Agreement (2004) — A dual-resident individual is deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home in both States, of the State with which his personal and economic relations are closer (centre of vital interests); if that State cannot be determined, or if he has no permanent home in either State, of the State in which he has an habitual abode; if he has an habitual abode in both States or in neither, of the State of which he is a national; in any other case the competent authorities settle the question by mutual agreement. Not amended by the 2019 Protocol.
s. 2(1) ITA 1947 (definitions of «year of assessment» and «basis period»); IRAS — preceding-year basis of assessment — Tax is charged for a year of assessment (YA) on the income of the preceding calendar year: YA 2027 covers income from 1 January to 31 December 2026. Residence is determined for the same preceding calendar year, so the selected year 2026 is the basis year for YA 2027.
Art. 24 Singapore–Germany Agreement (2004, as amended 2019) — Germany (para. 1): income from Singapore that Singapore may tax under the Agreement is exempt from German tax but taken into account for the rate; Germany credits the Singapore tax instead on dividends (other than qualifying intercompany dividends), interest, royalties, gains on shares in property-rich companies (Art. 13(2)), directors' fees and artistes' income; activity and switch-over clauses apply. Singapore (para. 2): (a) credits the German tax on income from Germany against Singapore tax on that income; (b) German income received in Singapore is exempt where the conditions of ss. 13(7A), 13(8) or 13(12) of the Income Tax Act are met.
Art. 22 Singapore–Germany Agreement (remittance clause, as replaced 2019) — Where a State reduces its tax under the Agreement on income that the other State taxes only on the amount remitted to or received in that other State, the reduction applies only to the amount so remitted or received — not where Singapore exempts the income under Art. 24(2)(b).
s. 13(7A) ITA 1947 — Exempt is income from sources outside Singapore received in Singapore: (a) by a non-resident individual; (b) from 1 January 2004 — by a resident individual, where the Comptroller is satisfied that the exemption is beneficial to him or her; the exemption does not cover such income received through a partnership in Singapore.
IRAS — «Claiming foreign tax credit» — Where foreign income is taxable in Singapore and foreign tax has been paid on it, a resident can claim a foreign tax credit in the return; the credit is the lower of the foreign tax paid and the Singapore tax payable on that income.
Art. 15(2) Singapore–Germany Agreement (2004) — Remuneration of a resident of one State for employment exercised in the other State is taxable only in the first State if the recipient is present in the other State for not more than 183 days in aggregate in any twelve-month period commencing or ending in the calendar year concerned, the remuneration is paid by or on behalf of an employer who is not a resident of the other State, it is not borne by a permanent establishment or fixed base of the employer in the other State, and the remuneration is subject to tax in the first State.
§ 2(7), § 32b EStG — Income tax is assessed annually. In the year of arrival or departure, worldwide income for the period of unlimited liability and German-source income for the rest of the year are combined; foreign income and treaty-exempt income raise the tax rate (Progressionsvorbehalt).
§ 6 AStG; § 17(1) first sentence EStG — A person whose unlimited German tax liability ends and who at any time in the last five years held at least 1% of the capital of a corporation is taxed on the increase in value of the shares as if they had been sold (exit taxation); payment in instalments is possible on application.
Art. 13(6)–(7) Singapore–Germany Agreement (as amended 2019) — Gains from the alienation of property not covered by the preceding paragraphs are taxable only in the State of residence of the alienator (para. 6); where an individual was a resident of one State for at least five years and becomes a resident of the other State, the first State may tax the gains on shares in companies resident there for the period of his residence in that State (para. 7).
IRAS — gains from the sale of property, shares and financial instruments (updated 27 February 2026); dividends (updated 27 February 2026) — Gains from selling property and shares are generally not taxed as capital gains unless the sale amounts to trading (frequent transactions, a profit-seeking motive). Dividends of Singapore companies under the one-tier system are not taxed; foreign dividends received in Singapore by a resident are generally not taxed either (except those received through a partnership in Singapore).
Arts. 18–19 Singapore–Germany Agreement (as amended 2019) — Pensions and annuities paid from one State to a resident of the other State are taxable only in the State of residence (Art. 18(1)); benefits under the statutory social insurance of a State are taxable only in that State (Art. 18(2)); since the 2019 Protocol, withdrawals from the Singapore Supplementary Retirement Scheme (SRS) by a resident of Germany are taxable only in Singapore, and German pensions based on contributions that were tax-relieved in Germany for more than five years are taxable only in Germany (Art. 18(4)). Government pensions are taxable only in the paying State unless the recipient is a resident and a national of the other State (Art. 19(2)).
Art. 20 Singapore–Germany Agreement (2004) — A student or business apprentice from the other State who is present solely for education or training is not taxed on payments from sources outside the host State for maintenance, education or training (para. 2); para. 1 contains a separate rule for visiting professors and teachers staying up to two years.
Deutsche Rentenversicherung — Germany's social security agreements — Germany has bilateral social security agreements with, among others, Japan, Canada/Quebec, the Philippines, South Korea, Türkiye and the United States, and a secondment agreement with China; Malaysia, Singapore and Taiwan are not listed (checked 10.11.2026).
Certificate of residence under a DTA (Finanzamt) — The local tax office (Finanzamt) issues the certificate: fill in the foreign authority's form or the German form «Ansässigkeitsbescheinigung nach DBA» (formulare-bfinv.de), sign it and submit it in two copies; one copy is returned signed and sealed. Free of charge.
IRAS — «Claim of relief under the DTA» (withholding tax, updated 8 January 2026) — To apply a reduced treaty rate or an exemption, the Singapore payer obtains a certificate of residence of the non-resident payee from the other state's tax authority (in English or with an English translation, stating residence for treaty purposes and the years covered); non-resident professionals also sign Form IR586. The payer submits the certificate to IRAS by 31 March of the following year, otherwise the relief may be withdrawn.
EStG
Art. 4(2)(a) of the Singapore–Germany Agreement — A dual-resident individual is deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available in both States, of the State with which his personal and economic relations are closer (centre of vital interests).
Art. 4(2)(b) of the Singapore–Germany Agreement — If the State of the centre of vital interests cannot be determined, or if he has no permanent home available in either State, he is deemed to be a resident of the State in which he has an habitual abode.
Art. 4(2)(c), (d) of the Singapore–Germany Agreement — If he has an habitual abode in both States or in neither, he is deemed to be a resident of the State of which he is a national (c); in any other case the competent authorities settle the question by mutual agreement (d).

Case law

Bundesfinanzhof (BFH), 1st Senate, I R 58/16, 24/07/2018 — A Wohnsitz under § 8 AO does not require a minimum number of days actually spent in the dwelling each year; even irregular visits can maintain a domicile. A person can have several domiciles at the same time.
Bundesfinanzhof (BFH), 1st Senate, I R 38/13, 13/11/2013 — A dwelling is any premises suitable for living in, even modest ones; what matters is that the person can use them at any time they wish and keeps them for their own residential use.
Bundesfinanzhof (BFH), 3rd Senate, III R 6/20, 12/11/2020 — Whether the circumstances indicate an intention to retain and use a dwelling is mainly a question of fact in each individual case.
Bundesfinanzhof (BFH), 1st Senate, I R 26/10, 22/06/2011 — Short interruptions count towards the six-month period of presence; there is no fixed limit on days of absence — they are assessed in light of the length of the whole stay.
Bundesfinanzhof (BFH), 1st Senate, I R 74/16, 23/10/2018 — Having a home abroad does not exclude unlimited tax liability in Germany, even where the foreign home is the centre of vital interests. The centre of vital interests matters only when applying a double tax treaty.

Updated 10/11/2026. The result is for information only and is not tax or legal advice. IRAS, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law can change with each annual Budget. Consult a qualified adviser before making decisions.

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