A new era of tax transparency begins in Austria in 2025 with the introduction of public Country-by-Country Reporting (Public CbCR). The Austrian CbCR Publication Act (CBCR-VG), published in the Federal Law Gazette BGBI I 83/2024 on July 17, 2024, implements Directive (EU) 2021/2101, amending the EU Accounting Directive. The EU Implementing Regulation 2024/2952, published on […]
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Amount B of Pillar One offers a simplified transfer pricing approach for distribution entities of multinationals that meet certain criteria. In 2024, the OECD published the Amount B guidance, incorporated as an Annex to Chapter IV of the OECD Transfer Pricing Guidelines, and provided lists of covered and qualifying jurisdictions (follow the links to access […]
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The EU introduced the Public Country-by-Country Reporting (CbC Report, or CbCR) Directive in November 2021 by which a vast number of multinational enterprises (MNEs) in the member states are obliged to publicly display corporate income tax data. Austria published a first draft of implementing this Directive into Austrian tax law in April 2024. While many […]
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On 4 April 2024, the Austrian Federal Ministry of Justice published the consultation draft on the “Austrian Federal Act on the Publication of Country-by-Country Reports (CbCR) on Income Tax Information”. This legislation transposes Directive (EU) 2021/2101 amending the EU Accounting Directive regarding the publication of income tax information by specific companies and branches into Austrian […]
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Within the framework of the BEPS 2.0 project a preliminary report on Pillar One – Amount B (launch version) was published on 19 February 2024 as a response to the public consultation documents (December 2021 & July 2023). The final report, including the outstanding work currently being completed, was expected by the end of March […]
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Under the BEPS 2.0 project the OECD published another public consultation document on Amount B of Pillar One on 17 July 2023. Stakeholders were invited to provide input until 1 September 2023. The declared goal of Amount B is to simplify and streamline the application of transfer pricing regulations for baseline marketing and distribution activities, […]
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On 21 December 2021, a new EU Directive (“Directive (EU) 2021/2101”) entered into force. Under the Directive, companies are required to publish a so-called “report on income tax information” (“Public CbCR”). Romania was the first EU Member State to implement the directive into national law. Therefore, for financial years beginning on or after 1 January […]
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Almost a year after the publication of the draft Transfer Pricing Guidelines, on 7 October 2021 the Austrian Federal Ministry of Finance has finally issued the new Austrian Transfer Pricing Guidelines (ATPG 2021 or Guidelines). Being an extensive revision of the Transfer Pricing Guidelines from 2010 (TPG 2010), the ATPG 2021 aim at reflecting BEPS-project […]
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