On 7 March 2025 the BFG Vienna has ruled in two appeals (RV/7103283/2023 and RV/7102685/2022) that the prohibition on deduction of low-taxed intra-group interest and royalty payments (section 12 para. 1 subsec. 10 Austrian Corporate Income Tax Act (KStG)) is a violation of the EU’s freedom of establishment. An ordinary review of the ruling to […]
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By decree dated 8 August 2023, Russia suspended the application of most parts of the double taxation agreement (DTA) Austria-Russia. After Austria successfully and congruently also suspended the agreement at the beginning of December 2023, the Austrian tax authorities published a decree on the effective date of the suspension and the unilateral elimination of the […]
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The deadline for the first DAC7 report (report according to DPMG (Austrian Digital Reporting Requirement Act)) is 31 January 2024. Just before the holiday season starts, we would like to inform you once again about upcoming deadlines and the most important to-dos that still need to be done. Deadlines and immediate need for action The […]
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After Russia unilaterally suspended the application of major parts of the provisions of the double taxation agreement (DTA) with Austria in August 2023, Austria has now suspended parts of the DTA as well. This has further implications for Austrian taxpayers. Background By decree dated 8 August 2023, Russia suspended the application of provisions from more […]
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On 12 September 2023 the BMF published an update on the Austrian DAC6 guidance which has been long anticipated. In addition to clarifications the guidance includes further explanations on hallmarks, on information of other intermediaries as well as on the content of the report. Background In mid-October 2020 the Austrian BMF has published a guidance […]
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On 12 September 2023 the European Commission has published the proposal for a directive for a European framework for corporate income taxation (“Business in Europe: Framework for Income Taxation”; BEFIT). BEFIT contains a proposal for the introduction of a Europe-wide tax group including a partially single tax base for certain large groups of companies in […]
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By decree of 8 August 2023, Russia unilaterally suspended the application of major parts of the provisions of the double taxation agreement between Austria and Russia. This has implications for Austrian taxpayers. Background In response to Western sanctions (such as the EU adding Russia to its “blacklist”), the Russian Foreign Ministry and the Russian Ministry […]
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With the Austrian Digital Platform Reporting Requirement Act (DPMG) entering into force on 1 January 2023, operators of certain digital platforms are now obligated for the first time to report to the Austrian Tax Authority among others tax-relevant information on reportable suppliers concerning the year 2023 by 31 January 2024. The BMF has now released […]
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Starting with 2024 the Austrian tax authority receives information on persons using digital platforms for renting and selling. If you use digital platforms for renting and selling you should absolutely keep an eye on the following amendment: The Austrian Digital Platform Reporting Requirement Act (DPMG) entered into force on 1 January 2023. The DPMG requires […]
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Special attention necessary where Russian participating interests are involved The most recent meeting of the EU finance ministers (ECOFIN) resulted in changes to the list of non-cooperative jurisdictions for tax purposes. On 14 February 2023, the finance ministers of the EU member states resolved to add four jurisdictions to the blacklist. Besides the Russian Federation, […]
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