Will We See a Change in Tax Treaties between European Countries Concerning Taxation of Occupational Pensions?

This article highlights the importance of the issue of occupational pensions in Europe. It analyses the tax treatment of occupational pensions in Europe, in general, as well as their treatment under both the OECD Model (2010) and select tax treaties of Member States. In particular, the author indicates that there is an emerging trend in tax treaties amongst Member States to grant the source country a right to tax.