Treaty relief

Double tax treaties decide which country may tax which income. For performers, almost all of them contain an artist clause (Article 17 in the OECD model): the country where the show takes place may tax the fee, wherever the artist lives. That is why Austrian artist tax is usually due for artists from Germany or the United Kingdom too.

Relief applies where a treaty takes that right away. Examples as of 1 October 2026: the treaty with Hungary has no artist clause, and under the treaty with Germany a visit funded wholly or mainly from German public money is taxed only where the artist lives.

How it works in Austria

The promoter may apply the relief when paying, but doesn’t have to (DBA-Entlastungsverordnung). It needs form ZS-QU1 (individuals) or ZS-QU2 (companies) in the original, signed by the artist and certified by their tax authority. Up to €10,000 per recipient and calendar year, a written declaration with the details the regulation lists is enough. If the paperwork falls short, the promoter is liable. Without relief at source, the artist claims the tax back afterwards.

Example

A club in Vienna books [Artist A] from Budapest for €1,200. With the signed declaration (under €10,000 a year) and no artist clause in the treaty, the club can pay the full €1,200 instead of withholding €240.

What to watch for

• Germany. There, a promoter can generally withhold less only with an exemption certificate (Freistellungsbescheinigung) from the BZSt. Without one, the full tax is withheld, even if a treaty would allow less.
• Agencies. If the fee goes to an agency, relief at source needs the artist’s name and address and the amount passed on, in writing. Without them it is ruled out (§ 5 DBA-Entlastungsverordnung).

This is general information, not tax advice. Check your case with a tax adviser.