Public Country-by-Country Reporting & Tax Transparency

The EU introduced the Public Country-by-Country Reporting (CbC Report, or CbCR) Directive in November 2021 by which a vast number of multinational enterprises (MNEs) in the member states are obliged to publicly display corporate income tax data. Austria published a first draft of implementing this Directive into Austrian tax law in April 2024. While many […]

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Update on the suspension of the double taxation agreement Russia – Effective date & unilateral elimination of double taxation

By decree dated 8 August 2023, Russia suspended the application of most parts of the double taxation agreement (DTA) Austria-Russia. After Austria successfully and congruently also suspended the agreement at the beginning of December 2023, the Austrian tax authorities published a decree on the effective date of the suspension and the unilateral elimination of the […]

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Draft legislation on “Public CbCR” published

On 4 April 2024, the Austrian Federal Ministry of Justice published the consultation draft on the “Austrian Federal Act on the Publication of Country-by-Country Reports (CbCR) on Income Tax Information”. This legislation transposes Directive (EU) 2021/2101 amending the EU Accounting Directive regarding the publication of income tax information by specific companies and branches into Austrian […]

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BFG confirms: Relief from KESt at source only with timely certificates of residence on the ZS-QU2 form

In its decision dated 24 January 2024 (RV/1100179/2019), the Austrian Federal Financial Court (BFG) confirms the strict view of the Austrian tax authorities that, in order to be granted relief from capital gains tax (KESt) at source based on the applicable double taxation agreement, it is compulsory for the certificate of residence to be submitted […]

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Minimum Tax Act (MinBestG) published in the Austrian Federal Law Gazette (BGBl)

Just in time for the turn of the year, the Minimum Tax Act was published in the (digital) Austrian Federal Law Gazette I on 30 December 2023, thus completing the legislative process. Overview The statutory provisions entered into force on 31 December 2023 and are applicable to financial years beginning on or after 1 January […]

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First DAC7 report is due – what needs to be done at the turn of the year?

The deadline for the first DAC7 report (report according to DPMG (Austrian Digital Reporting Requirement Act)) is 31 January 2024. Just before the holiday season starts, we would like to inform you once again about upcoming deadlines and the most important to-dos that still need to be done. Deadlines and immediate need for action The […]

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Austria counters Russia’s suspension of the double taxation agreement by suspending the agreement as well

After Russia unilaterally suspended the application of major parts of the provisions of the double taxation agreement (DTA) with Austria in August 2023, Austria has now suspended parts of the DTA as well. This has further implications for Austrian taxpayers. Background By decree dated 8 August 2023, Russia suspended the application of provisions from more […]

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Austrian Ministry of Finance (BMF) publishes a consultation draft for a Minimum Tax Act (MinBestG)

On 3 October 2023 the BMF has published a consultation draft for an act to ensure a Global Minimum Tax (Pillar II). The consultation period ends on 20 October 2023. The new regulations will enter into force as of 1 January 2024. The Minimum Tax Act transposes into domestic law the complex framework of the […]

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Update on the DTA Austria-Germany: new provision on cross-border workers and implementation of the MLI

The provision on cross-border workers has been adapted by the protocol of amendment to the DTA between Austria and Germany to enhance the tax framework for mobility of work close to border. Additionally, several provisions have been adjusted to the new OECD standards. New provision on cross-border workers The provision on cross-border workers is a […]

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Russia suspends parts of the double taxation agreement with Austria

By decree of 8 August 2023, Russia unilaterally suspended the application of major parts of the provisions of the double taxation agreement between Austria and Russia. This has implications for Austrian taxpayers. Background In response to Western sanctions (such as the EU adding Russia to its “blacklist”), the Russian Foreign Ministry and the Russian Ministry […]

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