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How to count 183 days

Under most tax treaties (Article 15(2) of the OECD Model), your salary for work done in another country is taxed only at home if you spend no more than 183 days there and two more conditions are met. Here is how the days are counted.

Three conditions together

If even one condition fails, the work country may tax the salary.

Which days count

The OECD counts days of physical presence. Any part of a day counts as a full day:

Which days do not count

Which period

The OECD Model uses any 12-month period starting or ending in the tax year — every possible 12-month window is checked, including overlapping ones. Older treaties use the calendar or tax year. Always read the treaty that applies to you: our treaty pages show the period for each pair of countries.

Not the same as residence days

Domestic residence tests (for example 183 days in a calendar year, or the US substantial presence test with weighted days over three years) are separate rules with their own counting. The treaty 183 days decide who taxes the salary; domestic days decide whether you are resident.

Common mistakes

When to see a professional

Sources

Sources checked: 10/11/2026. General information, not legal advice. Treaties and national laws can differ from the OECD Model; always check the treaty that applies to you.

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