Die Bedeutung der Saving Clause für die Anwendung des DBA Österreich-USA

Art. 1 (4) of the tax treaty between Austria and the United States contains the so called saving clause. Under this provision, the contracting states - in practice especially the U.S. - reserve the right to tax their citizens and resident aliens as if the treaty had not come into effect. Gerald Toifl describes the content of this regulation and pays special attention to its consequences in practice.