Eva Burgstaller, Michael Schilcher
Abstract
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.
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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.
Key concepts: Tax treaty, Subject (documents), Treaty, Legislation, Context (archaeology), Political science, Law and economics, Tax law