Authorisation as CBAM declarant – important updates!

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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Austrian Federal Tax Court (BFG): prohibition on deduction of low-taxed intra-group interest and royalty payments contrary to EU law

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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Austrian Public CbCR: What You Need to Know

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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Pillar II: New OECD documents and BMF information published in January 2025

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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Pillar II: Regulation with additional clarifications on CbCR Safe Harbors released

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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Pillar II: (Potential) reporting obligation by December 31, 2024 upon appointment of Austrian Pillar II Taxpayer

The global minimum tax (Pillar II) entails not only complex calculations but also various compliance obligations. Although the filing of the GloBE Information Return and the Austrian Pillar II advance notification is not due until 2026, one compliance issue may already require action by December 31, 2024. The Pillar II rules are applicable from January […]

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VAT in the digital age (“VIDA”) – Agreement in ECOFIN

On 8 December 2022, the European Commission submitted a draft for a Council Directive on the initiative “VAT in the Digital Age” (ViDA) including the long-awaited proposals for modernising VAT rules in the EU. On 5 November 2024, these were adopted unanimously by the Council of the European Union. In general, the proposal for the […]

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Resolved and planned legal amendments in the area of the Austrian Value Added Tax Act (UStG) and the EU Deforestation Regulation

In October 2024, due to the Austrian Progression Compensation Act 2025, there was an amendment to the UStG. Furthermore, the European Commission and the Council have adopted an amendment to the EU Deforestation Regulation. Amendment to the UStG The turnover limit for the applicability of the small business exemption will be raised from EUR 42,000 […]

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BMF (Austrian Federal Ministry of Finance) on value added tax on one-way packaging

The BMF confirms that deposits on one-way packaging are not part of the taxable base for Value Added Tax (VAT) purposes for the concerned beverage deliveries and are therefore not subject to VAT. Also, returning the deposit amounts when returning the one-way beverage packaging is not subject to VAT. Description As of 1 January 2025, […]

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Intrastat – New developments when using the One Stop Shop (EU OSS) for distance sellers located outside of Austria

Since January 2024, an amendment in connection with the Intrastat reporting obligations is applied regarding distance sellers located outside of Austria. Amendment as of the reporting year 1 January 2024 No Intrastat declaration obligation applies anymore as of the reporting year 1 January 2024, if economic operators not located in Austria arrange for intra-Community distance […]

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