New letter ruling on permanent establishments in the case of auxiliary activities within a company group

On 1 June 2021, the Austrian Ministry of Finance (MoF) published EAS (Express Answer Service) 3432. In this letter ruling, the MoF confirmed its previous view that there is only one set of circumstances in which activities, which by their nature constitute preparatory or auxiliary activities, do not lead to the creation of a permanent establishment […]

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Avoidance of claim interest and reduction of pre-payments for CIT and IIT – applications can be made until 30 September or 31 October 2020

Reminder: Down payments to avoid claim interest for corporate income tax and individual income tax for the year 2019, as well as applications for the reduction of pre-payments for corporate income tax and individual income tax 2020, need to be made by 30 September 2020! Applications for reductions due to COVID-19-related revenue losses can continue to be […]

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Austrian Ministry of Finance on permanent establishment issues related to the COVID-19 pandemic

Due to the COVID-19 prevention measures, many employees have for several months been unable to carry out their activities at the location at which they would normally have worked before the pandemic. In cross-border circumstances, this can lead to undesired changes in taxation rights between states – for example, due to the creation of permanent […]

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COVID-19 and international tax law: OECD on permanent establishments and residence status

The measures to control the COVID-19 pandemic have caused severe restrictions on international mobility. In international tax law, this could lead to unintended changes in the right to tax between countries, such as through the creation of a permanent establishment (PE) or a change in the place of effective management for companies operating internationally. The […]

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