On 21 December 2021, a new EU Directive (“Directive (EU) 2021/2101”) entered into force, amending the EU Accounting Directive. Under the Directive, companies are required to publish a so-called “report on income tax information” (also referred to here as “Public CbCR”). The goal of Public CbCR is to introduce an instrument for increasing transparency and enhancing […]
Proposal for an EU Directive on ensuring a global minimum level of taxation (‘Pillar 2’)
On 22 December 2021, the European Commission published its proposal for a Council Directive to introduce a global minimum effective tax rate for large multinational groups and large-scale domestic groups operating in the European Union. This is intended to implement the OECD Pillar 2 rules (‘Model Rules’) in the EU Member States. The OECD Model Rules were […]
Austrian National Council approves COVID-19 support measures in tax law
On 21 December 2021, the Austrian Parliament passed two legislative packages on pandemic-related support measures. These concern both tax relief in the Income Tax Act (EStG), Corporate Income Tax Act (KStG), VAT Act (UStG) and others, as well as simplifications in connection with tax payments. Here we have provided an overview of the key points: Income […]
Eco-social tax reform 2022: Changes to the draft legislation
On 15 December 2021, the bill of the Austrian Eco-social Tax Reform Act 2022 was published. Below we provide an overview of the most relevant changes between the consultation draft and the bill (see German Tax Newsletter of 12 November 2021): Tax-free employee participation in profits From the year 2022, employees are to be eligible […]
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 […]
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 […]
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 […]
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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