Decree on foreign activity
The Foreign Activity Decree (ATE) authorizes the tax authorities in the cases of Section 34c (5) and Section 50 (4 ) of the Income Tax Act to exempt employees with unlimited tax liability who work abroad from taxation .
This is only possible if
- it is a domestic employer,
- there is no double taxation agreement with the country ,
- the duration of the activity is more than three months without interruption and
- the activity is related to the installation or maintenance of assets, the prospecting or extraction of mineral resources or development aid is provided.
