Die geänderte Auslegung der "Künstler- und Sportlerklausel" im DBA mit Deutschland

On January 1, 1997, a decree of the Federal Minister of Finance, Federal Law Gazette No. 735/1996, on the interpretation of Article 8 of the Austro-German Double Taxation Convention ("artistes and sportsmen"-article) became effective. This was motivated by a unilateral modification of the German administrative practice in the taxation of residents of Austria deriving income from commercial activities exercised in Germany in their capacity as sportsmen. Heinz Jirousek describes the contents...