07.11.2022

New approach to withholding tax relief for personnel leasing

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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21.06.2022

Changes concerning withholding tax for Software-as-a-Service and Infrastructure-as-a-Service

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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