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Can special attraction regimes lead to treaty residence? Sergio I. Mutis

By: Mutis, Sergio I.
Material type: ArticleArticlePublisher: 2018Subject(s): REGIMENES ESPECIALES | RESIDENCIA FISCAL | FISCALIDAD INTERNACIONAL | TRATADOS INTERNACIONALES | AUSTRALIA | PORTUGAL | ESPAÑA | SUIZAOnline resources: Click here to access online In: Bulletin for International Taxation v. 72, n. 9, September 2018, 8 p.Summary: This article analyses if it is possible for individuals under special attraction regimes to be considered residents of a Contracting State under Article 4 of the OECD Model (2014). For this purpose, the regimes enacted by Australia, Portugal, Switzerland and Spain, as well as some of their tax treaties, are briefly examined.
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Resumen.

This article analyses if it is possible for individuals under special attraction regimes to be considered residents of a Contracting State under Article 4 of the OECD Model (2014). For this purpose, the regimes enacted by Australia, Portugal, Switzerland and Spain, as well as some of their tax treaties, are briefly examined.

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