The agreement between the Republic of Austria and the Kingdom of Greece originally reproduced on this page dated from 1970.
This agreement is outdated and has been replaced by a revised double taxation agreement which, following the pattern of other Austrian renegotiations of that period, is modelled on the OECD Model Convention. The Austrian government justified the renegotiation on the grounds that the 1970 agreement no longer met the requirements of modern economic life. The revised agreement is currently available, as applicable federal law, in the Austrian Legal Information System (RIS) under the title “Double Taxation – Taxes on Income and on Capital, including Protocol (Greece)”, and is itself modified by the BEPS Multilateral Instrument (MLI, effective since 2021).
As, on our review, the earlier treaty text no longer reflects the law currently in force, we have deliberately refrained here from reproducing the superseded 1970 wording of the agreement. We strongly recommend obtaining the current, complete text of the agreement directly via the Austrian Legal Information System (ris.bka.gv.at) or the Greek Ministry of Finance, and only then republishing the corresponding page.
For context: this agreement is one of more than 55 double taxation agreements Greece has concluded with other states, including all other EU member states; readers with tax matters connecting Greece to a country other than Austria should consult the relevant agreement for that country, or our general overview of Greece’s double taxation agreements.
Subject Matter of the Agreement (General)
Like the Germany – Greece agreement, the Austria – Greece DTA governs the allocation of taxing rights over business profits, dividends, interest, royalties, income from employed and self-employed work, and income from immovable property, the avoidance of double taxation through the credit or exemption method, and the mutual agreement procedure between the tax administrations of both states. It remains in force for an indefinite period and may be terminated by either contracting state, giving at least six months’ notice, with effect from the end of a calendar year.
FAQ
The agreement serves to avoid double taxation in the field of taxes on income and on capital for persons resident in one or both contracting states.
Covered, on the Austrian side, are income tax and corporate income tax (the Austrian net wealth tax was abolished in 1994), and on the Greek side, income tax and taxes on capital, as well as all taxes of an identical or substantially similar nature levied in future in addition to, or in place of, the existing taxes.
A person is resident who, under the law of a contracting state, is liable to tax there by reason of their domicile, permanent residence, place of management, or any other similar criterion. Where a natural person is resident in both states, regard is had, in turn, to the permanent home, the centre of vital interests, habitual abode, and finally nationality.
A permanent establishment includes, in particular, a place of management, branches, offices, factories and workshops, mines, and building sites or installation projects whose duration exceeds a specified period. Mere storage, exhibition or delivery facilities, and preparatory or auxiliary activities, do not constitute a permanent establishment.
Business profits are in principle taxed only in the state in which the enterprise is resident. Where a permanent establishment is maintained in the other contracting state, the profits attributable to that permanent establishment are taxed in the other contracting state.
Dividends, interest and royalties may in principle be taxed in the recipient's state of residence, with the source state retaining a right of withholding tax within a framework set out in the agreement. In the state of residence, the tax levied in the source state is generally credited.
Income from immovable property may be taxed in the contracting state in which the property is located (the situs state). The same generally applies to capital gains from immovable property.
The agreement combines the exemption and credit methods. Certain income is exempted in the state of residence (where applicable, subject to the progression proviso), while for other income the tax levied in the source state is credited against the tax owed in the state of residence.
The competent authorities are, in Austria, the Federal Ministry of Finance, and in Greece, the Ministry of Finance. They may resolve difficulties or doubts as to the interpretation or application of the agreement by mutual agreement, and exchange information to the extent necessary for the implementation of the agreement.
As of June 2026. All information on these pages is provided without guarantee or liability.