Can Special Attraction Regimes Lead to Treaty Residence?
Journal
Country
Australia; Portugal; Spain; Switzerland
Published Date
Issue
Bulletin for International Taxation 2018 (Volume 72), No. 9
Document
This article analyses if it is possible for individuals under special attraction regimes to be considered residents of a Contracting State under Article 4 of the OECD Model (2014). For this purpose, the regimes enacted by Australia, Portugal, Switzerland and Spain, as well as some of their tax treaties, are briefly examined.