How can US citizens in Germany invest in ETFs without PFIC or PRIIPs problems?

• One common path for US citizens in Germany is to hold US-domiciled ETFs through a US brokerage that serves expats -- this generally avoids PFIC classification, and PRIIPs typically does not block a trade executed at a broker's US entity.
• The catch: with a German address, not every broker keeps your account at its US entity. Where your account legally sits, not your passport, tends to decide whether you can still buy US ETFs.
• Charles Schwab International and Interactive Brokers are the two most commonly named options for US expats in Germany, with important differences in what each allows from a German address.
• Funding a US brokerage from Germany is straightforward using international wire transfers or services like Wise.
• If you already hold EU-domiciled funds, the situation is manageable but requires careful planning around whether to sell, hold, or transition.

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Not every US broker will keep your account active after you move to Germany. Here's the landscape as it stands.

Interactive Brokers accepts US citizens with German addresses and is the broker most expats name first. The detail that matters, and that most overviews miss, is which legal entity holds your account:

• Your address decides the legal entity, not your passport: IBKR assigns accounts to a legal entity by country of residence. A German address generally places the account at Interactive Brokers Ireland, an EU-regulated entity. PRIIPs applies there, so as a retail client you typically cannot buy US-domiciled ETFs like VTI or VOO, even as a US citizen. Existing US-domiciled holdings can usually be held, transferred in, and sold; new purchases are what may be blocked.
• What can still work: individual US stocks, US options and bonds, and holding or selling US ETF positions transferred in from another broker.
• Workarounds some clients use: qualifying as an elective professional client under MiFID (portfolio-size and trading-frequency tests most private investors do not meet, and the status removes retail protections), or acquiring ETF shares by exercising options. Both have real downsides.
• Multi-currency accounts: IBKR supports both USD and EUR balances, which simplifies funding from a German bank account.
• Trading costs: the commission-free IBKR Lite plan is only available to accounts opened with a US legal residence. From Germany, expect IBKR Pro's low (but not zero) commissions.
• Tax documents: 1099 forms (1099-B, 1099-DIV) come from IBKR's US entity. An account at the Irish entity gets activity statements instead, and it counts as a foreign financial account for FBAR and Form 8938 purposes.

IBKR's entity assignments and product rules have changed over time. Before you rely on IBKR for new ETF purchases from Germany, confirm with them which entity will hold your account and what it can buy.

One consideration: IBKR's platform is powerful but not the most intuitive. Many find there's a learning curve, particularly around currency conversion and order types.

Schwab has long served the US expat community, and after its merger with TD Ameritrade, it remains a viable option.

• Schwab International accounts: designed specifically for US citizens living abroad, and the account stays at a US entity, so PRIIPs typically does not block your trades. In practice, US citizens in Germany have generally been able to keep buying US-domiciled ETFs through these accounts, but eligibility follows your country of residence and can change, so confirm what your account can buy before funding it.
• Phone and in-person support: Schwab has international service teams familiar with expat situations.
• Minimum balance: Schwab International accounts have historically had a $25,000 minimum to open, though this has varied over time. Worth confirming current requirements directly.
• Narrower product range than IBKR: Schwab International may restrict certain products (options, futures, margin) that the domestic platform offers.

For more detail on Schwab specifically, see our article on Charles Schwab options for US expats in Germany.

• Vanguard: generally does not support foreign-address accounts for new purchases. Existing holdings can typically be maintained, but new buys and even dividend reinvestment may be blocked. Many expats transfer their Vanguard holdings elsewhere.
• Fidelity: takes a similar approach to Vanguard with foreign-resident accounts. Not a reliable long-term option for active investing from Germany.
• Tastytrade: has reportedly continued to allow US ETF purchases for clients with EU addresses, because accounts stay at a US entity. Policies can change, so verify the current status before opening an account.

If you haven't moved to Germany yet, opening accounts while you still have a US address is significantly easier. Many find it valuable to set up an IBKR or Schwab International account before relocating, even if you don't fund it right away. Updating your address to Germany after the account is open is generally smoother than trying to open a new account with a foreign address from scratch.

Two caveats. Updating your address can move the account under the broker's rules for your new country: at IBKR that can mean a different legal entity, at most brokers new country-of-residence restrictions. Your holdings are typically preserved either way; new purchases are what may be blocked. And it must be a real address update: keeping a US mailing address to hide your residence from the broker creates compliance risk, as covered under the pitfalls below.

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With access to a US broker, you can build a straightforward portfolio using the same ETFs available to any US-based investor. The goal: broad diversification, low costs, and no PFIC headaches.

A two- or three-fund approach can work well and keeps both US and German tax reporting manageable:

Equity exposure:

• VTI (Vanguard Total Stock Market ETF) -- covers the entire US equity market
• VXUS (Vanguard Total International Stock ETF) -- covers developed and emerging markets outside the US

Bond exposure:

• BND (Vanguard Total Bond Market ETF) -- US investment-grade bonds
• Alternatively, AGG (iShares Core US Aggregate Bond) serves the same role

This combination provides global equity and bond exposure in three US-domiciled funds, with expense ratios well under 0.10%.

US-domiciled ETFs registered under the Investment Company Act of 1940 are regulated investment companies (RICs) for US tax purposes. They are explicitly excluded from PFIC classification. This means:

• No Form 8621 filing
• No excess distribution calculations
• No mark-to-market elections needed
• Standard qualified dividend and long-term capital gains rates apply

This is the single biggest advantage of maintaining access to US-domiciled products.

Living in Germany introduces a few wrinkles to consider when designing a portfolio:

• Currency exposure: your expenses are in EUR, but a US-heavy portfolio is denominated in USD. Many find that a meaningful allocation to international (non-US) equities through VXUS provides natural diversification, since the fund holds EUR-denominated and other currency assets.
• Bond duration and currency: holding US bonds (BND/AGG) means your "safe" allocation is in USD. For short-term needs, keeping cash in EUR at a German bank may be more practical than holding USD bonds.
• German Vorabpauschale (advance lump sum tax): Germany taxes fund holdings annually based on a deemed minimum return, even if you don't sell. This applies to US-domiciled ETFs held in any account. The amount is typically modest, but it's an item for your German tax return.

Individual stocks (as opposed to funds) don't trigger PFIC issues and aren't subject to PRIIPs. Some US citizens in Germany use individual stock positions to complement their ETF core, particularly if they have strong conviction about specific companies. This works for those comfortable with the concentration risk and who have portfolios large enough that individual positions still represent reasonable allocation sizes.

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One of the most common practical questions: how do you actually get money from your German bank account into a US brokerage?

The most straightforward method. From your German bank (Sparkasse, Deutsche Bank, N26, etc.), initiate a SEPA-to-wire transfer to your US brokerage's receiving bank. You'll need:

• The brokerage's ABA routing number (for domestic US wires) or SWIFT/BIC code (for international wires)
• The brokerage's account number for incoming wires
• Your account number at the brokerage (often required in the reference field)

Most German banks charge EUR 10-30 per international wire. The transfer typically takes 1-3 business days.

Wise offers competitive exchange rates and lower fees than traditional bank wires. The process:

1. Set up a Wise account (verify identity with your German address and US passport)
2. Add your US brokerage as a recipient using its bank details
3. Fund the transfer from your German bank via SEPA
4. Wise converts EUR to USD at the mid-market rate plus a small transparent fee (typically 0.4-0.6%)

Many expats find Wise to be the most cost-effective option for regular monthly transfers.

If you use Interactive Brokers, there's an additional option: deposit EUR directly into your IBKR account (they provide EU banking details for SEPA transfers) and convert to USD within the platform. IBKR's forex conversion spreads are extremely tight -- often just $2 per conversion. This can be cheaper than using Wise for larger amounts.

Automating the process helps maintain discipline:

1. Monthly SEPA transfer from your German bank to your US brokerage (or to Wise)
2. Convert to USD (at IBKR) or let Wise handle the conversion
3. Purchase ETFs once the funds settle (typically T+1 for the transfer, T+1 for the trade)

This cadence takes about 15 minutes per month once established.

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If you already own UCITS ETFs or other EU-domiciled funds purchased before you understood the PFIC implications, there are several paths forward.

Often the cleanest long-term path. Selling EU-domiciled funds and reinvesting the proceeds in US-domiciled equivalents removes future PFIC exposure. Considerations:

• German capital gains tax: selling triggers Abgeltungsteuer (flat tax on investment income) on any gains, at 25% plus solidarity surcharge. For equity funds, Germany's Teilfreistellung (partial exemption) typically leaves 30% of the gain tax-free, so the effective rate can be roughly 18.5% rather than 26.4%, which can change the break-even maths of selling.
• US capital gains: the same sale is reportable on your US return. Under the treaty, Germany has the primary taxing right on gains, so the credit generally happens on the US side, but the mechanics require attention.
• Wash sale rules: if you sell an EU-domiciled ETF tracking the MSCI World at a loss and immediately buy a US-domiciled ETF tracking the same index, US wash sale rules could defer the loss recognition. The IRS has never ruled on whether funds from different issuers tracking the same index are "substantially identical", and many practitioners treat them as not identical, but it is a judgment call. This only matters if selling at a loss.

If your EU-domiciled holdings are in a taxable account and the tax cost of selling is high (large unrealised gains), holding the existing positions while directing all new investments to US-domiciled ETFs is a reasonable compromise.

• You'll need to file Form 8621 annually for each PFIC holding
• Electing mark-to-market treatment can give more predictable tax outcomes than the default excess distribution method. The election generally must be made for the first year you hold the fund; a later election can trigger a deemed-sale catch-up, so timing matters
• Over time, as you sell positions or they become a smaller portion of your portfolio, the PFIC burden diminishes

Not all situations are the same. A small UCITS position with minimal gains may be worth selling immediately to simplify your tax life. A large position with substantial unrealised gains may be worth holding if the tax cost of liquidation outweighs years of Form 8621 filing costs.

A cross-border tax advisor can model the break-even point for your specific holdings.

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Investing as a US citizen in Germany means reporting the same income and gains to two tax authorities that use different rules, different forms, and different tax years (though both the US and Germany use the calendar year). Good records make this manageable; poor records make it expensive.

• Dividends received: reported as Einkünfte aus Kapitalvermögen (income from capital assets). As a US citizen you typically file a W-9 with your US broker, so the broker usually withholds no US tax; you pay the US tax through your annual return. Germany generally credits the US tax on dividends up to the 15% treaty cap. Fund income from a foreign broker goes on Anlage KAP-INV, not just Anlage KAP.
• Teilfreistellung and Sparer-Pauschbetrag: for funds that qualify as equity funds (which broad ETFs like VTI, VXUS, and VT typically do), 30% of distributions, realized gains, and the Vorabpauschale is generally tax-free in Germany. On top of that, the first EUR 1,000 of investment income per year (EUR 2,000 for couples filing jointly) is covered by the Sparer-Pauschbetrag.
• Capital gains realised: each sale needs a purchase date, purchase price (in EUR at the exchange rate on the date of purchase), sale price (in EUR at the exchange rate on the date of sale), and gain/loss calculated in EUR.
• Vorabpauschale: the deemed annual return on fund holdings, calculated with the official base rate (Basiszins) the Federal Ministry of Finance publishes each January. It is zero in years when the fund did not gain in value. Your Steuerberater can calculate it, but they need your year-end fund balances, because no US broker reports it.

• Form 1040 and Schedule D: standard reporting of dividends and capital gains in USD.
• FBAR (FinCEN 114): if your non-US financial accounts exceed $10,000 in aggregate at any point during the year, you must file an FBAR. This covers German bank and brokerage accounts, and also a brokerage account assigned to a broker's non-US entity, such as IBKR's Irish entity.
• Form 8938 (FATCA): if your foreign financial assets exceed the filing threshold ($200,000 on the last day of the year for single filers living abroad, or $300,000 at any time during the year; both thresholds double for married filing jointly), you must file this form.
• Foreign tax credits (Form 1116): to avoid double taxation on income taxed by Germany, you claim credits for German taxes paid.

• Download year-end statements from both your US and German accounts as soon as they're available (typically January-February).
• Track exchange rates: for capital gains, the IRS generally expects the spot rate on the transaction date, while the yearly average rate from its published tables is meant for recurring income like dividends. Apply each method consistently.
• Keep a simple spreadsheet logging each transaction with: date, ticker, shares, USD amount, EUR/USD rate, EUR amount. This single source of truth feeds both tax returns.
• Calendar reminders: US tax deadline for expats is June 15 (automatic extension) with a further extension to October 15 available. German tax returns are typically due July 31 of the following year, or later if filed by a Steuerberater.

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This is the single most common and costly mistake. A well-intentioned purchase of an iShares MSCI World UCITS ETF at a German broker can result in hundreds of dollars in additional tax preparation fees annually and potentially punitive tax rates. Always verify fund domicile before purchasing.

Re-opening a US brokerage account from a German address is harder than maintaining an existing one. If you have any US brokerage accounts, keep them open through your move, even if you don't plan to use them immediately.

Even though US-domiciled ETFs are held at a US broker, Germany taxes you as a resident on worldwide income. The Vorabpauschale applies to fund holdings regardless of where the account is domiciled. Missing this on your German return can result in penalties and back taxes.

Some expats maintain a US mailing address (family member, PO box, or registered agent) on their brokerage accounts. This can work for mail delivery, but if it's used to misrepresent your residence for regulatory purposes, it creates compliance risk. The distinction matters: having a US mailing address while your broker knows you live in Germany is different from pretending you live in the US.

Analysis paralysis is real. The regulatory complexity can make it tempting to leave money in cash indefinitely. For many, a simple two-ETF portfolio at an expat-friendly broker -- even if imperfect -- can beat years of uninvested cash losing purchasing power to inflation.

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This is purely illustrative, not a recommendation for any individual situation.

Starting point: US citizen is preparing to move to Munich. Has $150,000 in a Vanguard account (mostly VTI and VXUS), plans to open a German Girokonto (current account) on arrival.

Step 1 -- Establish expat-friendly brokerage access before the move: While still at a US address, open an account at a broker that serves expats and initiate an ACAT transfer of the Vanguard holdings. This preserves the existing US-domiciled ETF positions without selling. After the move, update the address honestly and ask the broker two questions: which legal entity now holds the account, and can it still buy US-domiciled ETFs? The answers decide where new money can go.

Step 2 -- Set up funding: Configure a monthly SEPA transfer of EUR 1,500 from the German bank to the broker's European banking details (or via Wise). Convert EUR to USD at the broker or let Wise handle the conversion.

Step 3 -- Invest monthly: Purchase additional VTI and VXUS (or a single total-world fund like VT) with the converted USD, at whichever of your accounts can still buy them. Keep a bond allocation in BND if appropriate for the risk profile.

Step 4 -- Track everything: Maintain a transaction log with EUR/USD rates. At year-end, download the broker's annual tax report and the detailed activity statement for the German Steuerberater.

Step 5 -- File taxes: The US return includes 1040, Schedule D, Form 1116 (for German taxes paid), and FBAR/8938 if thresholds are met. The German return includes Anlage KAP and KAP-INV for the fund income, typically with the Teilfreistellung applied and the US tax on dividends credited up to the 15% treaty cap.

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1. Audit your current holdings: identify which funds are US-domiciled and which are EU-domiciled. Check the fund's ISIN -- US-domiciled funds start with "US".
2. Verify or establish broker access: confirm that your existing US broker supports your German address, or open an account at Schwab International or IBKR. Ask specifically which legal entity will hold the account and whether it can buy US-domiciled ETFs from a German address. Supporting your address and allowing new ETF purchases are not the same thing.
3. Understand the regulatory backdrop: if you want to know why these restrictions exist rather than just how to work around them, read our companion piece on the regulations behind US ETF restrictions in Germany.
4. Get your records in order: start the transaction log now, even if it's just a spreadsheet. Your future self (and your tax advisors) will thank you.
5. Explore your options: cross-border investment planning is one of the areas where professional guidance adds the most value. Explore your options in a discovery call.

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⚠️ IMPORTANT LEGAL DISCLAIMER:

This content is for educational and informational purposes only and does not constitute financial, tax, legal, or investment advice. You should not rely on this information as a substitute for, nor does it replace, professional financial or tax advice. Always consult with qualified professionals (tax advisors, financial planners, lawyers) before making any financial decisions or taking any actions based on this information.

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Disclaimer: This article is general information about investment approaches and does not constitute legal, tax, or investment advice. Individual circumstances vary, and regulations change. Broker policies described here reflect the landscape at the time of writing and may have been updated since. Consult a qualified cross-border tax advisor and confirm current broker policies before making investment decisions. Learn more about financial planning with Financemate in a discovery call.