Last year, the frontier worker provision of Art 15 para 6 tax treaty with Germany was modified. Employees who spend more than 45 working days or more than 20 % of all their working days per year outside of the frontier zone are not covered under that provision. The Austrian Ministry of Finance takes the view that both the 45-day and the 20 % limit have to be calculated for each employment relationship separately. Michael Lang challenges that view: In case of more than one employment relationship, those limits have to be calculated for all these relationships together.
