Express Reply Service (EAS) 3357 deals with the taxation of interest received by a non-resident shareholder of an Austrian company that mainly engages in managing immovable property. According to the Austrian tax administration, the interest paid by the Austrian company should be subject to taxation in Austria pursuant to sec 98 para 1 no 5 letter b Austrian Income Tax Act, as, from an economic perspective, the immovable property of the company can be seen as collateral for the debt against the shareholder. Erik Pinetz and Alexander Zeiler analyze the arguments brought forward by the tax administration for this outcome and show the consequences of these arguments for other situations.