Art 4 of the tax treaty between Liechtenstein and Austria deviates from the OECD Model in the definition of residence of individuals. As an additional condition, Art 4 para 3 of the treaty states that the foreign police requirements for permanent residence must be met. Viktoria Oberrader analyzes whether the additional condition complements the criteria that establish residence according to Art 4 para 1 of the treaty or just the tiebreaker rules in Art 4 para 2 of the treaty.
