Treaty between Australia and Malaysia – Australian interpretative decision on definition of permanent home

The Australian Taxation Office released Interpretative Decision ATO ID 2012/93 that deals with a definition of a "permanent home available to the taxpayer" in the residence tie-breaker article of the Australia - Malaysia Income Tax Treaty (1980).

The taxpayer, after living in his own house in Australia, contacts to work in Malaysia for two years. The taxpayer anticipates that after two years he will return to Australia and leases his house for a fixed term of two yea…