The question of the classification of severance payments under tax treaty law has been the subject of intense debate. Until now, however, little attention has been paid to the question of the treatment of severance payments to German-Austrian frontier workers (Art 15 para 6 tax treaty between Austria and Germany). Due to recent judgments by German courts as well as legislative changes in Germany, this issue is currently becoming more topical. In this article, Christian Knotzer focuses on the classification of Austrian statutory severance payments in tax treaty law and discusses the implications for German-Austrian frontier workers.
