Subject I of the 2024 Congress of the International Fiscal Association, which will be held from October 27th to 31st, 2024, in Capetown, South Africa, deals with the finding of the meaning of nexus for taxes in the past, the present, and the future. In their Austrian branch report, Stefan Bendlinger and Daniel Blum describe and analyze the key connecting factors for taxation established by Austrian tax legislation and the rationale underlying these rules. In this article, the authors – by reference to the utilization criterion applied for defining limited tax liability with regard to independent services and labour – intend to highlight a key finding of their report: the Austrian income tax rules defining the limited tax liability of non-residents are partially outdated, show inconsistencies, and would require substantial reform by the legislator.
