Under the OECD model, a permanent home is any dwelling you have arranged and kept for your own lasting use. It can be owned or rented. What matters is that it is available to you continuously, and is not somewhere you stay only briefly.
Why it matters
If two countries both treat you as resident, the treaty tie-breaker in the OECD model looks first at where you have a permanent home available to you. If you have one in only one country, that usually settles it. If you have one in both, the test moves on to your centre of vital interests. Our article Two countries say I'm tax resident. Which one wins? covers the later steps.
What can count
- A house or flat you own.
- A flat you rent.
- A rented furnished room.
The OECD commentary says any form of home can be taken into account. Ownership is not required.
What usually does not count
- A place you use only for short trips, such as holidays, business travel or a course.
- Hotel stays.
The test is about availability. A home you can use at any time can count even when you are away from it. How often you actually stay there matters later, at the habitual abode step.
An example
Rahul, an Indian banker, moves to Dubai and signs a one-year lease on a flat in Business Bay. He keeps his flat back home empty and furnished, and stays there when he visits. Both flats are available to him at all times, so he has a permanent home in both countries. The tie-breaker then turns to where his personal and economic ties are closer.
Quick questions
Does the home have to be mine?
No. Under the OECD commentary, a rented flat or even a rented furnished room can count, if it is kept for your lasting use.
Do all treaties use the same wording?
Most follow the OECD model closely, but you should check the wording of the specific treaty.
Sources: OECD Model Tax Convention, Commentary on Article 4 (unofficial web edition); HMRC International Manual INTM154020: dual residents (OECD model tie-breaker).
General information as at October 2026, not advice. The examples are fictional and simplified, and the rules have conditions and exceptions not covered here. Take advice on your own circumstances, in each country involved, before acting.