Austria MOF Clarifies Taxation of Pension Income Under DTA, Protocols With Germany

The Austrian Federal Ministry of Finance April 9 posted online Federal Finance Court Decision No. RV/2100613/2025, clarifying the taxation of pension income under the 2000 DTA with Germany, last amended in 2023. The taxpayer, an Austrian resident, was a retired opera singer and received a pension from the German Theater Pension Fund, along with state social security benefits. The Austrian Tax Office treated the pension as fully taxable income. On appeal, the Federal Finance Court found that: 1) the taxpayer was subject to unlimited tax liability in Austria due to residence; 2) the fund qualified as an overseas pension fund ...