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5.5. Source Rules with Respect to Income Derived by Non-Residents


Dividends received from companies that are incorporated and registered in Austria and from foreign companies authorized to operate in Austria are deemed Austrian sourced.


Interest paid by Austrian  residents to non-residents is deemed Austrian  sourced.


Royalty fees paid for the use of intellectual property in Austria, is deemed Austrian  sourced.

Rental income

Rental income from property situated in Austria is deemed Austrian  sourced.

Service fees

Service fees paid to a non-resident are deemed Austrian  sourced if any of the following conditions are met:

  • The services are rendered within Austria
  • The services are  rendered outside  Austria for Austrian residents by non-residents or for earning income effectively subject to Austrian  tax