Subject-to-tax clauses in tax treaties

Journal
Author
Burgstaller, E.; Schilcher, M.
Country
Austria
Published Date
Issue
European Taxation 2004 (Volume 44), No. 6
FormatPDF
EUR
45
| USD
50 (VAT excl.)

The authors examine Austrian subject-to-tax clauses based on the context of the treaty and the interaction of the domestic legislation of the treaty partners. The wording, as well as structural and historical issues of the specific treaty, serve as the basis for the discussion.