The model sounds coherent: never stay anywhere longer than half a year, and so become taxable nowhere. In practice it rarely fails in the host country — there the arithmetic usually works. It fails on the two counters that keep running in the home country while you add up days in Bangkok and Tbilisi. This article sets out which connecting factors Germany and Austria retain after departure, why the rotation does not hold without a documented tax residency, and which vehicle — 1% or 0% — fits which travel pattern.
Three counters, not one
Anyone living location-independently keeps a table: country, entry, exit, total. That table captures exactly one of three counters — and the one that is least often the problem.
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Counter one — the host country
Every country you stay in has its own thresholds. 183 days is the most common figure, but neither the only nor the lowest one: some states connect to a rented dwelling, others to the centre of vital interests, others again count the calendar year rather than a rolling twelve-month period. This counter is plannable — it is in your table.
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Counter two — the home country
Unlimited tax liability in Germany and Austria does not end through absence but through the connecting factor falling away. As long as a dwelling remains available, this counter keeps running — regardless of how few days you spent in the country. It appears in no travel table, because it does not depend on days.
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Counter three — the period after departure
Even after a clean exit, effects persist: exit taxation on shareholdings in corporations (§ 6 AStG), since 2025 also on privately held fund and ETF units (§ 19 para. 3 InvStG), and extended limited tax liability for ten years (§ 2 AStG). None of them connects to presence; they connect to shareholdings, portfolio values, income sources and assets. This counter, too, is blind to day counts.
The order of work follows from that by itself, and it is exactly the reverse of what most people choose: counters two and three belong cleared before the rotation starts. Counter one is calendar maintenance from then on.
Counter two: what Germany and Austria retain
Germany — the dwelling is the connecting factor
Unlimited tax liability arises under § 1 EStG through residence or habitual abode. Habitual abode (§ 9 AO) is the familiar measure: more than six continuous months, short interruptions harmless. Residence (§ 8 AO) is the more dangerous connecting factor, because it knows no time threshold. It merely requires that you hold a dwelling in circumstances suggesting you will keep and use it.
That is a factual determination, not a formal one. Neither deregistration at the residents registration office nor a new passport entry ends it. What ends it is the demonstrable surrender of control: termination, handover record, return of keys, and where applicable a lease to third parties without any right of recall. The residual connecting factors that surface most often in practice are always the same three — the room at the parental home that is “still there”; the holiday flat let only by the week; the flat handed to a partner while the lease continues in your name.
Austria — 70 days and a register
Austria likewise connects through § 26 BAO to residence and habitual abode, but it has an explicit exception that Germany lacks: the Zweitwohnsitzverordnung (Federal Law Gazette II No. 528/2003). Under it, an Austrian dwelling constitutes a residence only where three conditions hold at once — the centre of vital interests has been abroad for more than five calendar years, the Austrian dwellings together are used for no more than 70 days per calendar year, and a register of that use is kept.
The third point is where it fails in practice. The register is not a formality but an element of the test: if it is not kept, unlimited tax liability applies — even where the 70 days were demonstrably observed. Anyone wanting to keep the Austrian flat therefore keeps a list from day one, not from the day the tax office asks.
Counter three: the ten years afterwards
Two provisions reach beyond departure, and both are independent of where you go next.
Exit taxation under § 6 AStG treats shares within the meaning of § 17 EStG — holdings of one per cent or more in corporations — as disposed of on departure. It is triggered where you were subject to unlimited tax liability for at least seven years within the preceding twelve. There is a returnee provision of seven years, extendable on application, and payment in seven equal annual instalments, as a rule only against security. For the typical perpetual traveller without shares in a limited company this runs into the void — for anyone holding shares in a German GmbH it is the single most expensive item of the whole project and belongs planned years ahead.
Since 2025 that provision no longer stands alone. The Annual Tax Act 2024 introduced § 19 para. 3 InvStG: giving up residence now also counts as a deemed disposal of investment fund units held privately, retail funds and ETFs included. It catches anyone who held at least 1 per cent of the units issued within the preceding five years, or who holds units with acquisition costs of EUR 500,000 or more per fund; the tax is payable in seven annual instalments on application. Anyone taking an ETF portfolio along checks that threshold before departure, not after.
Extended limited tax liability under § 2 AStG operates for ten years beyond the end of the year of departure. It applies only cumulatively: German citizenship, unlimited tax liability for at least five of the preceding ten years, residence in a low-tax territory — measured by a comparative calculation on EUR 77,000 of taxable income — and substantial economic interests in Germany. The latter exist, for example, where more than 30 per cent of your income or more than EUR 62,000 comes from German sources, or where your German assets exceed 30 per cent of total assets or EUR 154,000. The threshold for the income captured is EUR 16,500.
That list is the actual instruction. § 2 AStG is not fate but an enumeration of connecting factors — and every one of them can be dissolved before departure. What leaving costs in total, and in what order it should be planned, is set out in Staying is not getting cheaper.
The anchor is what makes the rotation viable
That poses the central question: once counters two and three are cleared, is it not enough simply to travel?
Legally, perhaps. Practically, no — for a reason that has little to do with tax. Every institutional counterparty in commercial life asks for a country of residence, not an itinerary: the bank at onboarding, the CRS self-certification, the payment provider, the broker, the insurer. A form field that admits no empty answer will be filled in eventually — either by you with a documented country, or by the other side with an assumption. The four breaking points of this model are set out in Statelessness is not a solution.
Georgia answers that question well for two reasons. First, it taxes resident individuals territorially: income without a Georgian source remains exempt under Art. 82 of the Georgian Tax Code. An anchor that generates no tax burden of its own is the only kind that works for this way of living. Second, access is low-threshold: around 95 nationalities may stay visa-free for 365 days, and residency arises after 183 days in any twelve-month period — not in the calendar year, and not consecutively.
Both routes to Georgian residency — 183 days, or the HNWI programme with its asset and property thresholds — are set out with all requirements in Tax residency in Georgia.
The vehicle: 1% or 0%
The structure follows the travel pattern, not the other way round. Two vehicles are available to location-independent sole operators, and they differ less in tax rate than in the route to residency.
| Individual Entrepreneur (1%) | US LLC, held directly (0%) | |
|---|---|---|
| Tax rate in each case with residency met and full declaration | 1% on turnover up to GEL 500,000 | 0% on the resident’s foreign income |
| Route to Georgian residency | 183 days — follows from the stay itself | HNWI programme only, if you are never in Georgia |
| Material entry hurdle | none | USD 500,000 property plus proof of assets or income |
| Travel pattern it fits | Georgia as a base, rotation in between | permanently on the move, Georgia only on paper |
| Stripe, US PayPal Business, US routing | ||
| Invoicing in your own name | ||
| Form 5472 + pro-forma 1120 USD 25,000 penalty per form and year — even with zero US tax | ||
| Excluded activities | Decree #415, including consulting | no Georgian restriction |
| Ongoing effort | monthly filing, one jurisdiction | two jurisdictions plus a gapless travel log |
For the large majority of perpetual travellers the left column is the right one — not because it is cheaper, but because it derives residency from the stay itself rather than from half a million dollars in property. The rotation then runs not against Georgia but around it: half a year as a base, half a year in the world.
One practical point that is often misunderstood: with the Individual Entrepreneur the business is legally bound to you as a private individual. Income may flow to any account you own, including a foreign one — Wise, Revolut and Payoneer are permissible, as long as all income is declared. The details of the status, including the activity exclusions and the monthly filing that has been mandatory even at zero turnover since 7 March 2026, are in Georgia: 1% tax with Small Business Status. Anyone who still wants to run the 0% model will find the full mechanics in Location-independent at 0%.
The calendar that survives an audit
A model resting on days of presence stands or falls with the provability of those days — years later, before an authority that does not carry the burden of proof. The list below is the short form of what actually has to be produced in an audit.
- Travel log with entry and exit dates per country, kept continuously — not reconstructed afterwards from the calendar
- In case of doubt both entry and exit day count; check per country whether the calendar year or a rolling twelve-month period applies
- Boarding passes, stamped passport pages and accommodation records as the evidence chain behind the log
- Proof that the home-country dwelling was given up: termination, handover record, cancellation with utility providers
- Where an Austrian flat is kept: a register of days of use under the Zweitwohnsitzverordnung, from day one
- Georgian certificate of residency applied for and archived per tax year — not just the TIN
- Keeping a second home in the country of departure "just in case" — the most common reason a departure is not recognised for tax purposes
- Letting travel turn into staying in a host country: annual lease, fixed coworking desk, local clients
- Leaving German income sources and domestic assets untouched and hoping § 2 AStG will not be examined
What follows from this
Perpetual travel works — but not because you stay nowhere for 183 days. It works when three things hold at once: the connecting factors in the home country are demonstrably dissolved, there is a documented residency that generates no tax burden of its own, and the vehicle matches actual travel behaviour rather than a desired tax rate.
The order is not negotiable. Anyone who incorporates first and deals with departure afterwards ends up, in the unfavourable case, with a foreign company managed from a German flat — and has created exactly the problem the structure was meant to avoid. How Georgia is set up as a base in practice is described in the twelve-month plan in Moving to Georgia; what applies specifically to remote workers is in Digital nomads in Georgia.
Frequently asked questions
If I never stay 183 days anywhere, am I taxable nowhere?
No. The 183 days are one connecting factor among several, not the only one. Germany establishes unlimited tax liability through a residence under § 8 AO — a dwelling available to you, with no day count at all. Austria connects the same way under § 26 BAO. Conversely, liability in your home country does not end because you fail to create one elsewhere. Being resident nowhere generally means not zero tax obligations but one unresolved obligation — and in case of doubt it is resolved by whichever authority asks first.
Is deregistering at the residents registration office enough to end German tax liability?
No. Deregistration is a matter of registration law; unlimited tax liability is a matter of tax law. What counts is § 8 AO (residence) and § 9 AO (habitual abode) — and for residence, a dwelling you hold and keep is sufficient. A room at your parents house with your own key, a holiday flat let only by the week, or a flat handed to your partner while the lease still runs in your name can preserve liability long after deregistration. Termination and handover records therefore belong among the first documents in your file.
What is extended limited tax liability — and does it hit me as a perpetual traveller?
§ 2 AStG extends limited tax liability for ten years after the end of the year of departure. It applies only cumulatively: German citizenship, unlimited tax liability for at least five of the ten years before it ended, residence in a low-tax territory, and substantial economic interests in Germany — the latter, for example, where more than 30 per cent of income or more than EUR 62,000 comes from German sources, or German-situs assets exceed 30 per cent of total assets or EUR 154,000. The threshold for the income captured is EUR 16,500. Anyone who leaves behind no German income sources and no meaningful German assets typically falls outside it — which is precisely why cutting domestic connecting factors matters more than counting days.
Can I keep a flat in Austria?
Yes, but only under the conditions of the Zweitwohnsitzverordnung (Federal Law Gazette II No. 528/2003). It requires three things at once: your centre of vital interests has been abroad for more than five calendar years, the Austrian dwellings together are used for no more than 70 days per calendar year, and a register of that use is kept. Without the register, unlimited tax liability applies — even where the 70 days were in fact observed. The ordinance is therefore less a permission than a documentation duty.
Why do I need a certificate of residency if I pay tax nowhere anyway?
Because practically every institutional counterparty asks for one, and none of them accepts an itinerary. Banks require a country of residence and a tax number at onboarding and in the CRS self-certification, payment providers require the same, and every double tax treaty presupposes a residency before it applies at all. Without that proof you later carry a burden of proof towards your country of departure that boarding passes alone will not discharge. Note: the Georgian tax number (TIN) is not a certificate of residency — the Revenue Service issues that only once the 183 days are met or HNWI status applies.
Individual Entrepreneur at 1% or US LLC at 0% — which suits perpetual travel?
That is decided by the route to residency, not by the tax rate. The Individual Entrepreneur presupposes that you actually use Georgia as a base — the 183 days then follow from the stay itself and you pay 1% on turnover up to GEL 500,000. The pure LLC model at 0% requires residency without presence, and that exists only via the HNWI programme with its USD 500,000 property threshold. On EUR 200,000 of turnover the difference is EUR 2,000 in tax — against a second jurisdiction including Form 5472 and a USD 25,000 penalty exposure. The LLC pays off if you need Stripe and the US market, not for the single percentage point.
This article is general information and does not constitute legal or tax advice. The German statements refer to § 1 EStG, §§ 8 and 9 AO and §§ 2 and 6 AStG, the Austrian ones to § 26 BAO and the Zweitwohnsitzverordnung (Federal Law Gazette II No. 528/2003), each as in force at the time of writing; the Georgian ones to the Tax Code (Art. 82) and the tax residency rules including the HNWI programme. Thresholds and connecting factors in third countries reflect the position in August 2026 and must be checked locally before any extended stay. Anyone who is or remains taxable in Germany, Austria or Switzerland must fully declare foreign entities, accounts and income there — always involve a tax adviser in your home country before relocating or structuring. As of August 2026, subject to changes in law.