With resolution dated 7 October 2025, the Austrian Supreme Administrative Court (VwGH) submitted key interpretative questions regarding the simplification rule for triangular transactions to the ECJ. The focus is on whether an invoice correction related to failed triangular transactions is possible and whether the invoice correction has ex nunc effect. VwGH 7 October 2025, Ro […]
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On 23 October 2025, the ECJ has commented on the VAT treatment of supplies of tooling equipment with reference to the legal case Brose Prievidza C‑234/24. Underlying case The German automotive component manufacturer Brose Coburg acquired specific tooling equipment from the Bulgarian supplier IME Bulgaria for the manufacture of components and sold it to the […]
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On 29 September 2025, the Council of the EU signed off on simplifications to the CBAM Regulation through the Omnibus package. The amendments seek to provide simplification and cost-efficient compliance improvements to the CBAM, taking effect from 1 January 2026. Please find the most important updates below: Setting a single mass-based threshold (de minimis rule) […]
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DAC7 – implemented in Austria by the Austrian Digital Platform Reporting Requirement Act (DPMG) – continues to pose major challenges for platform operators. After the second year of the DAC7 reporting obligation, there are still many uncertainties regarding the report, not least how to proceed if corrections are required after submitting the report. The German […]
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With its decision in the case SC Arcomet Towercranes(C-726/23) published on 4 September 2025, the ECJ takes a stance on VAT effects of transfer pricing adjustments (“TP adjustments”) for the first time. Description The SC Arcomet Towercranes SRL (subsidiary) is part of the Arcomet group. The Romanian subsidiary buys or rents cranes for selling or […]
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In the Implementing Regulation (EU) 2025/486 dated 17 March 2025, the European Commission has specified the conditions and procedures related to authorisation as CBAM declarant. Only authorised CBAM declarants may import CBAM goods from 1 January 2026! Importing CBAM goods without corresponding authorisation may result in sanctions after 1 January 2026. Please find the main […]
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On 7 March 2025 the BFG Vienna has ruled in two appeals (RV/7103283/2023 and RV/7102685/2022) that the prohibition on deduction of low-taxed intra-group interest and royalty payments (section 12 para. 1 subsec. 10 Austrian Corporate Income Tax Act (KStG)) is a violation of the EU’s freedom of establishment. An ordinary review of the ruling to […]
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A new era of tax transparency begins in Austria in 2025 with the introduction of public Country-by-Country Reporting (Public CbCR). The Austrian CbCR Publication Act (CBCR-VG), published in the Federal Law Gazette BGBI I 83/2024 on July 17, 2024, implements Directive (EU) 2021/2101, amending the EU Accounting Directive. The EU Implementing Regulation 2024/2952, published on […]
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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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