PwC Austrian Tax News - Archive 2013

Unser englischsprachiger Newsletter zu aktuellen österreichischen Steuerthemen erscheint sechs Mal jährlich. Er behandelt relevante Themen für internationale Unternehmen in Österreich: Direct und Indirect Taxes, Expatriates und Austrian Tax Facts & Figures.

Our english newsletter concerning latest austrian tax topics is published six times a year. It discusses relevant topics for international companies in Austria: Direct and Indirect Taxes, Expatriates and Austrian Tax Facts & Figures.

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Issue 43, December 2013

  • UFS: Merger of a group parent into a non-group company does not terminate the tax group
  • The concept of the economic employer in the case of personnel secondment
  • Indirect participation in German limited liability company
  • Austrian Independent Fiscal Senate: Availability of losses in spite of significant change of business parameters
  • International participation exemption for a domestic partnership with Liechtenstein shareholders
  • Salzburg Tax Dialogue 2013 – Highlights on VAT
  • VAT grouping in light of BFH jurisdiction
  • Energy taxes in Austria: Ministry of Finance releases Energy Tax Guidelines 2013
  • Austrian Tax Facts and Figures

Issue 42, September 2013

  • Salzburg Tax Dialog 2013
  • Highlights Salzburg Tax Dialog 2013 – Austrian Restructuring Tax Act
  • Conversion of a company after expatriation to Switzerland
  • Exit tax upon moving from Austria to Switzerland
  • Principle of “correct overall profit” vs. “correct period taxation” – Profit adjustments in periods not covered by a statute of limitations
  • Commercial activity tax of Ohio
  • VAT implications due to Croatia’s accession to the EU
  • Alternative Investment Funds Manager Act: The regulatory and tax impacts
  • Austrian Tax Facts and Figures

Issue 41, June 2013

  • Austrian Independent Fiscal Senate affirms goodwill amortisation on foreign group members
  • Increased foundation entrance tax rate for donations to foreign foundations
  • 2013 Corporate Tax Guidelines
  • Re-qualification of German property management partnership profits where business profits are derived from second level partnerships (“Abfärbetheorie”)
  • Open market value: a “new” VAT basis
  • Draft of the Company Law Amendment Act 2013 (GesRÄG 2013)
  • Unlawful repayment of equity in connection with debt financed acquisition of shares
  • Austrian Tax Facts and Figures

Issue 40, April 2013

  • Tax agreement between Liechtenstein and Austria
  • Liechtenstein – Update on Double Tax Treaty
  • Tax treatment of a Liechtenstein company under the Austria-Liechtenstein Tax Treaty
  • Decision of the Austrian Constitutional Court on the international participation exemption
  • Update on Double Tax Treaties
  • Capital duty on the absorption of losses by a company’s shareholder
  • UFS decision on leasing of space for servers
  • German Ministry of Finance restricts the simplification rule for intra-EU supplies of wholesaler goods (the “Pommes-frites-Erlass”)
  • Fight against tax evasion intensified

Issue 39, Februar 2013

  • Decree on informal ruling procedure by the Austrian Ministry of Finance
  • Direct shareholding requirement under the Austria-Switzerland Tax Treaty
  • Decision of the Austrian Administrative Court: Deduction of foreign losses for non-residents
  • Operating/property management partnership in Hungary – Treatment of profits at the level of the Austrian partner
  • Contribution into a non-existing company
  • Tax treatment of shareholder costs
  • Austrian private foundations – No roll-over of capital gains to the acquisition costs of a letter box company
  • Taxation of real estate transfers on the basis of standard tax values repealed
  • Value Added Tax Guidelines: Highlights of the 2012 update