Austria MOF Clarifies Taxation of Employment Income Under DTA With Germany

The Austrian Federal Ministry of Finance March 10 posted Federal Finance Court Decision No. RV/7101914/2024, clarifying the taxation of employment income under the 2000 DTA with Germany. The taxpayer, an individual employed in Austria from Feb. 1, 2021, maintained residences in Austria and Germany until Aug. 26, 2021, and earned part of his 2021 income in Germany. The Tax Office included the German income in the progression calculation when calculating the Austrian tax rate. The taxpayer argued that pre-residency income shouldn’t affect the progression calculation. On appeal, the Federal Finance Court found that: 1) the taxpayer was subject to unlimited ...