A further round of consultative talks with regard to the application of the Austro-German tax treaty has taken place in Vienna and has produced some interesting results as to the interpretation of the double taxation convention; some of such coordinated findings are:

• rents paid by German life insurance companies are to be taxed in Austria, no interest component of such rents may be subjected to a German source tax; this, however, does not apply where a one-time payment is made by the insurance company;

• costs of a German company incurred in the frame of its acquisition of a participation in an Austrian partnership have to be borne by Austria;

• salary payments that continue to be made after termination of the employment contract are
taxable in the country where the underlying dependent activity was performed;

• in the case of a man-power leasing contract the user of the hired out personnel may be regarded as being the employer of such personnel if their employment contracts with the man-power-leasing company have been entered into solely for the hiring-out-period;.

• amounts distributed in complete liquidation of a corporation are treated ...