SWI 2018, 179
In the following, the 183-day rule under Art 14 of the tax treaty between Austria and the Czech Republic will be examined. In counting the 183 days, a special provision is included in the tax treaty, which is unique in the Austrian treaty network. A sacrosanct principle of tax treaty law is even put into question by this special provision. Paul Hollaus deals with the provision and shows which effects it has for the practitioner.