FlagSagePermanent home
Glossary term
A permanent home, in tax treaty tie-breaker rules, is a home available to a person on a lasting basis, whether or not they own it.
Permanent home is usually the first tie-breaker test in a tax treaty. HMRC guidance says a dual resident is treated as resident in the country where they have a permanent home available to them, though not necessarily owned by them.
If the person has a permanent home in both countries, the next test is the centre of vital interests. If they have one in neither country, HMRC's helpsheet points to the habitual abode test.
The treaty test is separate from home tests in domestic law. The UK statutory residence test, for example, has its own home test with its own conditions. In the treaty test, what matters is whether the home is available, not who owns it.
Not to be confused with
- Habitual abode. Habitual abode is about where a person regularly lives, not about whether a home is available to them.
- Centre of vital interests. The centre of vital interests is the next test when a person has a permanent home in both countries.
Sources
- INTM154020 - Double taxation agreements: residence: Dual residentsOfficial guidance
- Dual residents 2026 (HS302)Official guidance
- RDR3: Statutory Residence Test (SRT) notesOfficial guidance
Related
- Countries covered
- General
- Sources
- 3 sources
- Tax year
- Current rules as checked
- Review
- Not professionally reviewed
Sources checked November 8, 2026