Austria MOF Clarifies Taxation of Severance Payments Under DTA With Germany

The Austrian Federal Ministry of Finance March 3 posted online Federal Finance Court Decision No. RV/3100205/2024, clarifying the taxation of severance payments under the 2000 DTA with Germany. The taxpayer, an Austrian resident, worked within a multinational group for Austrian subsidiaries and for German group companies from Austria. Upon the termination of his German employment, the taxpayer received a severance payment, which was taxed at Austrian standard rates. The taxpayer argued that portions of the severance qualified for the preferential 6 percent income tax rate. On appeal, the Federal Finance Court found that: 1) Austria had taxing rights under the ...