DT2754 - Double Taxation Relief Manual: Guidance by country: Austria: Notes

Artistes and Athletes (Article 17)

Protocol SI 1994 No. 768 provides that income derived by a resident of Austria from entertainment or sporting activities performed in the UK under a cultural agreement between the UK and Austria, or derived by a non-profit making organisation, or by an entertainer or athlete who provides services to such an organisation, is to be exempt from tax in the UK.

A similar exemption applies in relation to UK residents performing activities in Austria under such cultural agreements, etc.

Although the reference in Article 17 is to an “athlete” rather than the more usual “sportsperson”, the Article covers all sportspersons and not merely those involved in track and field athletics.

Teachers and researchers (Article 21)

The convention contains provisions relating to the taxation of visiting professors and teachers. Exemption from UK tax is due provided that the teacher’s etc. visit does not exceed two years and the teacher etc was a resident of Austria immediately preceding his visit to the UK.