What conditions must be met to apply for unlimited tax liability?

If you have neither a residence nor a habitual abode in Germany, you can apply to be treated as fully liable for income tax (fictive unlimited tax liability).

The conditions for this are:

• You are a natural person.
• You have domestic income.
• Your income is subject to German income tax for at least 90% of the calendar year, or the income not subject to German income tax does not exceed the tax-free allowance. The tax-free allowance in 2025 is 12.096 Euro for single persons and 24.192 Euro for married couples. The tax-free allowance may be reduced according to the country group classification of the Federal Ministry of Finance.
• You prove the amount of income not subject to German income tax with a certificate from the relevant foreign tax authority. For this purpose, you must submit the form "Certificate EU/EEA" or "Certificate outside EU/EEA" together with your tax documents.