Austria MOF Clarifies Taxation of Director’s Salary Under DTA With Japan

The Austrian Federal Ministry of Finance June 5 clarified the taxation of a director’s salary who resided in Japan but had temporarily established a place of residence in Austria. The individual was a managing director for companies in both countries. The clarification includes that: 1) the director is subject to unlimited tax liability in Austria but considered a resident of Japan based on his center of vital interests; 2) the remuneration from both managing director positions is classified as income from employment; 3) the Austrian remuneration falls under the classification of supervisory board remuneration as per Article 15 of the ...