In the frame of a mutual agreement procedure with Liechtenstein it was clarified that Liechtenstein follows the Swiss position according to which the allocation of taxing rights in a DTC cannot be altered through subsequent changes in domestic law. This position deviates from the general OECD-concept as laid down in Article 3 para. 2 of the Model Convention. As a result, remuneration received by Austrian shareholder-employees from their own companies in Liechtenstein can no longer enjoy tax exemption (associated with Article 14) but is subjected to the credit method (associated with Article 15) and is therefore taxable in Austria. In this particular case the departure of Liechtenstein from the OECD-concept is beneficial to the Austrian tax revenue (and is counteracting tax-driven manipulations).