On 21 December 2021, a new EU Directive (“Directive (EU) 2021/2101”) entered into force. Under the Directive, companies are required to publish a so-called “report on income tax information” (“Public CbCR”). Romania was the first EU Member State to implement the directive into national law. Therefore, for financial years beginning on or after 1 January […]
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A new decision of the Austrian Supreme Administrative Court (VwGH) (22.6.2022, Ro 2020/13/0004) was recently published regarding the definition of a “fixed place” under tax treaty law. For a fixed place to exist, a taxable person must have power of disposal over it. For Austrian tax purposes, a decisive hallmark of the existence of a […]
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On 5 May 2022, the Austrian Federal Ministry of Finance (“BMF”) published new guidance on mutual agreement procedure (“MAP”) and arbitration procedure (BMF – IV/8, Geschäftszahl 2022-0.300.851). The guidance replaces a BMF guidance from the year 2019 and provides an overview of the formal and material requirements for these procedures in Austria. Structure of the guidance […]
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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 […]
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Almost a year after the publication of the draft Transfer Pricing Guidelines, on 7 October 2021 the Austrian Federal Ministry of Finance has finally issued the new Austrian Transfer Pricing Guidelines (ATPG 2021 or Guidelines). Being an extensive revision of the Transfer Pricing Guidelines from 2010 (TPG 2010), the ATPG 2021 aim at reflecting BEPS-project […]
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