In a recently published decision of 25 July 2013 (2011/15/0193), the Austrian Supreme Administrative Court (Verwaltungsgerichtshof) ruled on the application of the residence tie-breaker rule for individuals under article 2A(2)(a) of the Austria - Ireland Income Tax Agreement (1966) (as amended through 2009) (the Treaty).

(a) Facts. In 2005 and previous years, the Taxpayer, an Aust…

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