The OECD Council approved the contents of the 2025 Update to the OECD Model tax Convention on Income and Capital (“OECD MTC”) on 18 November 2025. The most significant update relates t0 permanent establishments in the context of cross border home office arrangements (see our newsletter). In addition to that, it also covers other cross-border […]
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During the work on the update 2025 of the OECD model treaty and model commentary (hereinafter MC), the topic on the agenda, among other things, was the international mobility and the thereby growing cross-border remote work. As of 18 November 2025, the OECD has published an extensive update of the MC. The new specifications bring […]
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Country-by-Country Reporting (CbCR) serves to provide information that enables tax authorities to conduct an informed risk assessment of transfer pricing. In May 2025, the OECD published a new overview of common errors made in preparing CbC reports. The document updated the summary from November 2019 with further common errors, reaching a total of 28. As […]
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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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Amount B of Pillar One offers a simplified transfer pricing approach for distribution entities of multinationals that meet certain criteria. In 2024, the OECD published the Amount B guidance, incorporated as an Annex to Chapter IV of the OECD Transfer Pricing Guidelines, and provided lists of covered and qualifying jurisdictions (follow the links to access […]
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Within the framework of the BEPS 2.0 project, the report on Pillar One – Amount B (“Report on Amount B” or “the Report”) was published on 19 February 2024 and incorporated as an Annex to Chapter IV of the OECD Transfer Pricing Guidelines (for further details, please see our previous newsletter). Two supplements to the […]
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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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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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Within the framework of the BEPS 2.0 project a preliminary report on Pillar One – Amount B (launch version) was published on 19 February 2024 as a response to the public consultation documents (December 2021 & July 2023). The final report, including the outstanding work currently being completed, was expected by the end of March […]
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Under the BEPS 2.0 project the OECD published another public consultation document on Amount B of Pillar One on 17 July 2023. Stakeholders were invited to provide input until 1 September 2023. The declared goal of Amount B is to simplify and streamline the application of transfer pricing regulations for baseline marketing and distribution activities, […]
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