PwC Austrian Tax News

• Key points on tax in the Austrian government’s work programme, 2017-2022
• No application of loss-trafficking rules if de facto managing directors remain unchanged
• Austrian Supreme Administrative Court: Recapture taxation of foreign tax losses in the year prior to the dissolution of the CIT group
• Austrian Supreme Administrative Court Decision on the Attribution of Shares to a Permanent Establishment

• Update on the VAT guidelines
• Opinion of Advocate-General Bot on Austrian triangular transactions
• Concurrent employment of managing directors by another group GmbH triggers a second social security contribution
• Tax Facts and Figures

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• Indirect change of shareholders does not trigger losstrafficking rules
• Tax law amendment on the tax treatment of dividend distributions vs. capital repayments
• New Double Tax Treaty

• Case law: Right for input VAT deduction in connection with the disposal of shares
• Austrian Supreme Administrative Court on the retroactive effect of amendments of invoices and VAT deduction
• New Register for Ultimate Beneficial Owners (UBO Register)
• Austrian Tax Facts and Figures

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• Austrian Research Premium and Employment Bonus
• Austria's Position to the Multilateral Instrument (MLI)
• No import of foreign (final) losses despite transfer to place of management
• Austrian Supreme Administrative Court on the utilisation of ot yet utilised deferred write-downs of participations ("offene Siebentelabschreibungen")
• Electronic submission of CbC Report and CbCR notification

• Austrian Supreme Administrative Court on zero-rated intra-EU supplies of goods with interrupted delivery
• Fiscal criminal liability in connection with the recipient's obligation to withhold and pay VAT on supplies of goods (sec 27 (4) of the Austrian VAT Act)
• Net-wage assumption - a GPLA  (joint audit of wage-dependent levies)-related issue with expanded regulations as of 1 January 2017
• Austrian Tax Facts and Figures

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• "Brexit" - possible effects on revenue tax
• Update on Double Tax Treaties 2017
  
• Automatic exchange of information with Switzerland and Liechtenstein - changes based on AEI agreement
• Austrian Supreme Administrative Court on the deductibility of due diligence costs
• Alienation of shares of a limited liability company with immoveable property in Austria according to the Double Tax Treaty ("DTT") Austria - Australia

• Austrian Supreme Administrative Court on the economic link in VAT groups
• Recent decision of the Austrian Supreme Administrative Court on the tax treatment of severance payments under the Double Tax Treaty Austria-Germany
• Austrian Tax Facts and Figures

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• Deductibility of interest within a tax group
  
• Austrian Supreme Administrative Court (VwGH): attribution of losses from tax-exempt foreign group members to the group parent
  
• Envisaged exchange of information regarding cross-border rulings and advance pricing arrangements
  
• Supreme Administrative Court decision: consideration of operating expenses when determining withholding tax on personnel lease of employees
  
• The tax-related key points of the Federal Government's new work programme 2017/18

• Recent Changes in Value Added Tax
  
• Energy tax refund: Possibility to apply for an adjustment of prior years?
  
• Cross-border active and passive leases between group-entities
  
• Austrian Tax Facts and Figures

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