Austria MOF Clarifies Double Taxation Under DTA, Protocols With Germany

The Austrian Federal Ministry of Finance July 26 posted online Federal Finance Court Decision No. GZ. RV/2100440/2018, clarifying double taxation under the 2000 DTA with Germany, last amended in 2023. The taxpayer, resident in Austria, worked for an Austrian employer and took business trips to the employer’s place of business in Germany. The Tax Office found the proportionate wage income from the business trips for tax year 2013 was taxable in Austria. It found no proof that wage costs attributable to the business trips weren’t borne by the Austrian employer, but by the employer’s permanent establishment (PE) in Germany, or ...