In this article, René Matteotti and Alexandra Münger examine the classification of Swiss old-age and survivors’ insurance (AHV) pensions under tax treaties, in light of recent decisions of the Austrian Supreme Administrative Court of October 7th, 2025. The court classified AHV pensions as government service pensions within the meaning of Article 19 of the tax treaty between Austria and Switzerland, thereby allocating taxing rights to Switzerland as the paying state and accepting the resulting double non-taxation.
