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Austria
DLA Piper
In a landmark decision, the Federal Fiscal Court of Austria (BFG 21. 11. 2019, RV/7102891/2012) has granted an application for a full refund of withholding tax on dividends paid to a Canadian ...
Schoenherr Attorneys at Law
The aim of these possible changes is to lower the overall tax burden and to make the tax system more ecological.
Schoenherr Attorneys at Law
After several extensions and long negotiations, the United Kingdom is now set to leave the European Union on 31 January 2020, after which a transitional period will commence until 31 December 2020.
Schoenherr Attorneys at Law
In early April 2019, the Austrian Federal Government published a draft of the Digital Tax Act 2020 which is currently under review.
Wolf Theiss
Since January 2019, a new double taxation treaty between Austria and Japan is applicable, replacing the former treaty dating back to 1961.
Wolf Theiss
The double taxation treaty concluded between Austria and Germany contains a special provision deviating from the OECD Model Convention on the tax treatment of remunerations for employees living and working across the border ...
Schoenherr Attorneys at Law
Non-Austrian resident taxpayers deriving certain income from Austrian sources (e.g. dividends, royalties, consultancy fees for commercial and technical advice, leasing of personnel) are subject
Wolf Theiss
In this respect, exit tax is only triggered after such five-year period.
Wolf Theiss
The Austrian Ministry of Finance recently summarized the cases where residence certificates issued on non-Austrian forms will be accepted.
Wolf Theiss
As reported in Issue 2/2018 of our International Tax Newsletter, Austria introduced CFC legislation in line with the EU's Anti Tax Avoidance Directive, with effect for business years starting as of 1 January 2019.
Wolf Theiss
The Austrian Ministry of Finance recently dealt with an interesting case of dividend payments made from an Austrian corporation to the Austrian permanent establishment of a French indirect shareholder.
Wolf Theiss
On 23 October 2018, an amended double taxation treaty between Austria and the United Kingdom was concluded.
Wolf Theiss
Austria appears to have incorrectly applied a derogation in relation to the implementation of the interest limitation rule contained in the EU's Anti-Tax Avoidance Directive.
Wolf Theiss
Currently, Austria does not have controlled foreign company ("CFC'' legislation.
Wolf Theiss
Summer has already arrived - this means it's time for the next issue of our International Tax Newsletter. In this edition, we have included major updates from the CEE/SEE region.
Schoenherr Attorneys at Law
The taxation of cryptocurrency transactions is a hot topic. The Austrian Ministry of Finance recently issued an interesting ruling outlining when mining for cryptocurrencies in Austria by a non-resident taxpayer...
Wolf Theiss
Pursuant to the Austrian Supreme Administrative Court, for the purposes of the provision stipulating a forfeiture of tax loss carry-forwards ...
European Union
Schoenherr Attorneys at Law
According to EU figures there are currently 2,000 tax disputes pending between Member States, and approximately 900 of them are over two years old.
Wolf Theiss
On 12 September 2017, the European Court of Justice decided for the first time as an arbitral tribunal on a tax dispute between Austria and Germany (case C-648/15).
Wolf Theiss
We hope you enjoyed the holidays and are now curious to read the next issue of our International Tax Newsletter.
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