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 Austrian resident individual, was receiving employment income from his work as carpenter. Between March …