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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The provision on cross-border workers has been adapted by the protocol of amendment to the DTA between Austria and Germany to enhance the tax framework for mobility of work close to border. Additionally, several provisions have been adjusted to the new OECD standards. New provision on cross-border workers The provision on cross-border workers is a […]
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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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For the Austrian Ministry of Finance (BMF), the ruling of the Austrian Supreme Administrative Court (VwGH) of 23 April 2021 (Ra 2020/13/0089) provided the impetus to conduct a pragmatic overhaul of withholding tax relief in the form of the Ordinance on Withholding Tax Relief for Personnel Leasing. Initial situation As foreign employers are subject to limited […]
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Under many Austrian double tax treaties, the remuneration for “industrial, commercial or scientific equipment” is treated as royalties subject to withholding tax (WHT). In a change from the previous interpretation, the Austrian Ministry of Finance has now stated that intangible assets (e.g. software) do not fall under the category of “equipment”. This has significant implications […]
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