Shortly after the start of the new year, we would like to inform you about the following developments in the field of Global Minimum Taxation / Pillar II: OECD: Three new Administrative Guidances and GloBE Information Return documents published On 15 January 2025, the OECD published three Administrative Guidances with further clarifications. The following topics […]
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The foundation for applying the transitional CbCR Safe Harbor in the context of the Global Minimum Taxation is a qualified country-by-country report (CbCR). A CbCR is deemed qualified only if it is prepared based on a qualified data basis. The regulation issued by the Federal Minister of Finance on December 5, 2024, provides further clarifications […]
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The global minimum tax (Pillar II) entails not only complex calculations but also various compliance obligations. Although the filing of the GloBE Information Return and the Austrian Pillar II advance notification is not due until 2026, one compliance issue may already require action by December 31, 2024. The Pillar II rules are applicable from January […]
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On 3 May 2024, the Austrian Ministry of Finance (BMF) published a draft of the AbgÄG 2024 (Austrian Tax Amendment Act 2024; AbgÄG 2024). This draft includes, in particular, the following significant amendments: Income tax With the AbgÄG 2023, contributions of a partner into its partnership are treated two- sided for income tax purposes: Whilst […]
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Just in time for the turn of the year, the Minimum Tax Act was published in the (digital) Austrian Federal Law Gazette I on 30 December 2023, thus completing the legislative process. Overview The statutory provisions entered into force on 31 December 2023 and are applicable to financial years beginning on or after 1 January […]
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On 3 October 2023 the BMF has published a consultation draft for an act to ensure a Global Minimum Tax (Pillar II). The consultation period ends on 20 October 2023. The new regulations will enter into force as of 1 January 2024. The Minimum Tax Act transposes into domestic law the complex framework of the […]
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On 15 December 2022, the Council of the EU formally adopted the directive on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union. Hungary was the last EU member state to agree to the EU directive, the required unanimity has been reached. Therefore, EU member states […]
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