The idea sounds coherent: resident nowhere, taxable nowhere, always on the move. In theory it works. In practice it fails routinely — and not at the tax office but at account opening. This article shows the four points at which the model breaks, and why the answer is not “no residence” but “the right one”.
The four breaking points
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The bank wants an address
No reputable institution opens an account without proof of residence. That is not obstruction but part of the due-diligence duties under anti-money-laundering rules. Anyone without an address does not get past the first step of account opening — and without an account every tax model stays theoretical.
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CRS wants a tax number
At onboarding the bank asks for your tax residence and has it confirmed in writing. Anyone unable to state one is not left unreported — they become conspicuous. In practice an unclear self-certification leads to rejection or to reporting into several states rather than to no reporting at all.
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Without residence there is no treaty protection
Double taxation treaties protect persons resident in a contracting state. Anyone resident nowhere cannot invoke any treaty. Withholding taxes then remain in full — which hits dividends, interest and royalties, precisely the income types typical of this audience.
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The country of origin does not let go immediately
For German nationals section 2 AStG applies: anyone subject to unlimited tax liability for at least five of the previous ten years who moves to a low-tax jurisdiction while retaining substantial economic interests at home remains under extended limited tax liability for ten years.
The fourth breaking point is the most interesting, because it defeats the model on its own logic: section 2 AStG does not require a new residence. The provision bites where someone moves to a low-tax jurisdiction — and anyone resident nowhere cannot demonstrate that they moved to a normal-tax one. The absence of a residence is therefore not protection but a missing exculpatory proof.
Why the right residence achieves the opposite
This is exactly the point. What the model sets out to achieve is achieved more reliably with a clean residence than without one.
| Without a fixed residence | With Georgian residence | |
|---|---|---|
| Account opening the most common practical hurdle | Routinely fails on proof of residence | Address and residence status available |
| Self-certification at CRS onboarding clarity is an advantage here, not a weakness | Unclear, leads to rejection or multiple reporting | Unambiguous, with a tax number |
| Treaty protection including Germany, Austria and Switzerland | None — withholding taxes remain in full | Residence certificate available, treaty network with 60+ states |
| Foreign investment income dividends, interest, foreign rents | Taxed depending on source state | 0% under Art. 82 Georgian Tax Code |
| Physical presence required freedom of movement is preserved | Constant relocation necessary | None — tax residency after 183 days or via the HNWI programme |
That is the actual reason Georgia works for location-independent entrepreneurs: not because it requires no residence, but because it enables a demonstrable residence without a presence requirement. 365 visa-free days for EU and DACH nationals, tax residency after 183 days within any twelve-month period, alternatively the HNWI programme with no minimum stay. Details in Georgia Tax Residency.
What follows from this
The question is not whether residence can be avoided. The question is which one you choose.
A residence is not a disadvantage to be minimised — it is the infrastructure on which everything else is built: the account, treaty protection, invoicing, retirement provision and, when it matters, health cover. Optimising it away means optimising away the foundation.
The durable route for location-independent entrepreneurs is therefore unspectacular: a real residence in a country with low rates, no presence requirement, functioning banking and a treaty network. What leaving Germany or Austria costs beforehand is in Staying Does Not Get Cheaper; what the operating model alongside it looks like is in Georgia 1% Tax with Small Business Status.
Frequently asked questions
Can one genuinely be taxable nowhere?
In theory yes, in practice rarely on a lasting basis. Most states link unlimited tax liability to a residence or habitual abode; anyone consistently avoiding both escapes that connecting factor. The model usually fails not on tax but on infrastructure: banks require proof of residence, double taxation treaties presuppose a residence, and the country of origin does not let go immediately.
Why is account opening the main problem?
Because proof of residence is a fixed component of due-diligence duties under anti-money-laundering rules. No reputable institution opens an account without an address. Added to that is the self-certification of tax residence at CRS onboarding: anyone unable to state one is not left unreported but becomes conspicuous — with rejection or reporting into several states as the likely outcome.
What is extended limited tax liability?
Section 2 AStG covers German nationals who were subject to unlimited tax liability for at least five of the previous ten years, move to a low-tax jurisdiction and retain substantial economic interests at home. For ten years after departure, certain domestic income remains taxable on an extended basis. Notably, the provision does not require a new residence — so the absence of a residence offers no protection from it.
What is a residence certificate good for?
It is the evidence a contracting state requires before a double taxation treaty is applied. Without it, withholding taxes remain in full — which particularly affects dividends, interest and royalties. Georgia maintains treaties with Germany, Austria and Switzerland as well as more than 60 further states, and issues the certificate to tax residents.
Does Georgia require physical presence?
For tax residency the 183-day rule within any twelve-month period applies; alternatively there is a programme for high-net-worth individuals with no minimum stay. EU and DACH nationals may stay visa-free for 365 days. There is no presence requirement for running a company — so freedom of movement is preserved, just without the price of having no residence at all.
Is this not just another tax model?
It is a residency model with low rates, and it works only if the relocation is real: centre of life, giving up the residence in the country of origin, actual management on the ground. Anyone establishing residence on paper while in fact living in Germany does not have a model but a risk. That difference is precisely the one that matters in a dispute.
This article is general information and does not constitute legal or tax advice. The legal references relate to section 2 of the German Foreign Tax Act, the OECD Common Reporting Standard and the consolidated Georgian Tax Code (Art. 82) as in force at the time of writing. Foreign accounts and income must be declared in your country of residence. As of May 2026, subject to changes in the law.