Tax issues for international companies in Austria
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Transfer Pricing Guidelines) provide orientation when applying the arm’s length principle. On 20 January 2022, the OECD published a new version of these Transfer Pricing Guidelines. It is available in English and French on the OECD website. The OECD Transfer Pricing Guidelines 2022 replace […]
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On 21 December 2021, a new EU Directive (“Directive (EU) 2021/2101”) entered into force, amending the EU Accounting Directive. Under the Directive, companies are required to publish a so-called “report on income tax information” (also referred to here as “Public CbCR”). The goal of Public CbCR is to introduce an instrument for increasing transparency and enhancing […]
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Shortly before the end of 2021, the European Commission (EC) presented a proposal for an Anti-Tax Avoidance Directive (so-called “ATAD 3”) to prevent the misuse of shell (or letterbox) entities. The planned directive envisages extensive reporting obligations for shell entities, which may potentially lead to a loss of tax benefits (e.g. arising from application of […]
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Here we discuss various issues related to customs legislation which frequently cause problems from a tax advisory perspective. To protect yourself from higher charges and liability under tax criminal law, special attention needs to be paid to these issues to ensure that all relevant values have been recognised in the customs declaration. Here we provide […]
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The Austrian Supreme Administrative Court (VwGH) has decided that in the event of an asset deal (e.g. sale of a building) with singular succession (rights transferred individually), a new lease agreement is created for VAT purposes. In practice, this means that after the sale, a lease of business premises that is subject to VAT is […]
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On 22 December 2021, the European Commission published its proposal for a Council Directive to introduce a global minimum effective tax rate for large multinational groups and large-scale domestic groups operating in the European Union. This is intended to implement the OECD Pillar 2 rules (‘Model Rules’) in the EU Member States. The OECD Model Rules were […]
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On 21 December 2021, the Austrian Parliament passed two legislative packages on pandemic-related support measures. These concern both tax relief in the Income Tax Act (EStG), Corporate Income Tax Act (KStG), VAT Act (UStG) and others, as well as simplifications in connection with tax payments. Here we have provided an overview of the key points: Income […]
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On 15 December 2021, the bill of the Austrian Eco-social Tax Reform Act 2022 was published. Below we provide an overview of the most relevant changes between the consultation draft and the bill (see German Tax Newsletter of 12 November 2021): Tax-free employee participation in profits From the year 2022, employees are to be eligible […]
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The yearly amendment to the Austrian VAT Guidelines (UStR) was published on 6 December 2021. Here we provide you with an overview of the most relevant changes: Changes in connection with VAT groups In items 233 and 241, the Guidelines have been amended to reflect CJEU case law regarding the cases M-GmbH (CJEU 15.4.2021, C-868/19) and Danske […]
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In addition to the annual adjustments for Intrastat-declarations (e.g. update of CN8-Codes), new regulations will apply as of the reporting month January 2022 due to the regulations (EU) 2019/2152 und (EU) 2020/1197. In the following, we summarize the most important key aspects. Information to be reported The following information must be indicated: The nature of […]
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