Tax treatment of cross-border pensions under the OECD Model and EU law

Abstract

This article summarizes the proceedings of the seminar on cross-border pensions at the 2008 IFA Congress in Brussels. The panel considered four topics: cross-border pension contributions, portability of pension rights, taxation of the pension fund's investment income, and allocation of taxing rights. The article discusses these topics in light of the OECD Model and in light of EU law. The discussion of allocation of taxing rights addresses, among other things, the question of determining the source of a pension for treaty purposes.