SolvedDT2753 | Double Taxation Relief Manual: Austria: Treaty Summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Austria are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 10% (Note1) | 10 |
| Dividends on direct investments | 0% | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a company which controls directly or indirectly 10% of the voting power in the company paying the dividend; or a pension scheme | 10 |
| Property income dividends | 15% | 10 |
| Interest | 0% | 11 |
| Royalties | 0% | 12 |
| Government pensions | Taxable only in Austria unless the individual is a national of the United Kingdom without also being an Austrian national | 18 |
| Other pensions | Taxable only in the UK (Note 2) | 17 |
| Arbitration | Yes | 23 |
Note 1: Other than where the beneficial owner of the dividend is a pension scheme in which case the rate is 0%.
Note 2: Lump-sum payments derived from a pension scheme established in Austria are taxable only in Austria.