According to the European Commission, approximately 70% of retail investors waive claims for refunds and 30% of retail investors sell their foreign EU stocks due to complicated refund procedures for WHT. On 19 June 2023 the Commission has published a proposal for a Directive for simplifying withholding tax procedures on interest and dividends, which shall […]
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On 31 March 2023, the Austrian Federal Ministry of Finance published the approx. 360-page final Income Tax Guidelines Amendment Decree 2023. This decree is intended to update the Austrian Income Tax Guidelines (EStR), in particular by incorporating the changes from the Austrian Ecosocial Tax Reform Act 2022 Part I (ÖkoStRefG), the Austrian Tax Amendment Act […]
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29The grace period for taxpayers with tax representation to submit tax returns for 2021 has been extended by the Austrian Ministry of Finance from one month (31 March to 30 April 2023) to six months (30 September 2023). Tax returns (e.g. individual and corporate income tax returns or annual VAT returns) must be submitted by […]
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Special attention necessary where Russian participating interests are involved The most recent meeting of the EU finance ministers (ECOFIN) resulted in changes to the list of non-cooperative jurisdictions for tax purposes. On 14 February 2023, the finance ministers of the EU member states resolved to add four jurisdictions to the blacklist. Besides the Russian Federation, […]
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As a general rule, section 13 para. 4 KStG permits Austrian private foundations to carry over hidden reserves from the sale of investments (in which the foundation or its legal predecessor held a share of at least 1% within the last five years) to substitute investments. These substitute investments must involve the acquisition of a […]
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In principle, section 9 para. 5 Austrian Corporate Income Tax Act (KStG) provides that a merger within the company group does not result in the merging company exiting the company group or in other changes to the company group. The Austrian Supreme Administrative Court addressed a special situation in its decision of 19 October 2022, […]
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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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On 21 December 2021, a new EU Directive (“Directive (EU) 2021/2101”) entered into force. Under the Directive, companies are required to publish a so-called “report on income tax information” (“Public CbCR”). Romania was the first EU Member State to implement the directive into national law. Therefore, for financial years beginning on or after 1 January […]
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For the first time, in its decision of 7 October 2022, RV/7101680/2022, an Austrian Tax Court had the opportunity to look into the relation between section 9 para. 6 subsec. 7 Austrian Corporate Income Tax Act (KStG) (reduction of subsequent taxation in the event of liquidation) and section 10 para. 3 KStG (assertion of partial […]
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As previously reported in our Tax Newsletter of 14 June 2022, the grace period for the submission of tax returns for 2020 for taxpayers with tax representatives was initially extended by three months (from 31 March 2022) to 30 June 2022 and then again to 30 September 2022. The Austrian Ministry of Finance (BMF) has […]
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