PwC Austrian Tax News - Archive 2016-2017

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

Our English newsletter which outlines the latest Austrian tax issues is published four times a year. It deals with relevant topics for international companies in Austria, including direct and indirect taxes, expatriates and Austrian tax facts & figures.

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Issue 59, December 2017

  • 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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Issue 58, September 2017

  • 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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Issue 57, June 2017

  • "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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Issue 56, March 2017

  • 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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Issue 55, December 2016 

  • CbCR – upfront notification to the tax office
  • Update on Double Tax Treaties: Double Tax Treaty between Austria and Iceland
  • Austrian Supreme Administrative Court: Cash contributions and write-downs in Austrian tax groups
  • Recent decisions of the Austrian Supreme Administrative Court (VwGH) on the tax treatment of jouissance rights
  • Austrian Supreme Administrative Court: Up-stream merger of the head of an Austrian tax group into a non-group company terminates the tax group

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  • Austrian company cars – VAT burden for Austrian employees of foreign taxable persons
  • Update: PoS systems in Austria: New decrees by the Austrian Ministry of Finance
  • Austrian Supreme Administrative Court on chain supplies
  • Evidence requirements for triangulation supplies: update
  • Austrian Tax Facts and Figures 

Issue 54, September 2016

  • Austria implements new transfer pricing documentation and country-by-country reporting requirements effective from 2016
  • ECJ update on energy tax refund
  • New documentation requirements to qualify for the withholding tax exemption at source under a tax treaty or based on the EU Parent Subsidiary Directive
  • VAT treatment of employee benefits Draft legislation following the Salzburger Steuerdialog 2016

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  • Austrian Federal Ministry of Finance specifies its clarification for the evidence requirements for triangulation supplies of goods not qualifying for the simplification rule
  • Austrian Supreme Administrative Court on invoicing requirements
  • VAT in connection with the on-charging of educational expenses
  • Austrian Tax Facts and Figures

Issue 53, June 2016

  • Independence of auditors of public-interest entities
  • Update on the Austrian energy tax refund and the ECJ
  • Austrian Ministry of Finance clarifies evidence requirements for triangulation supplies not qualifying for the simplification rule
  • VAT treatment of supplies with fractional transport
  • Applications to the Austrian tax authority sent by e-fax or e-mail inadmissible

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  • Austrian Administrative High Court (VwGH) extends scope of the Austrian goodwill amortisation to EU/EEA targets
  • VAT: New developments for consignment stocks
  • Update: PoS systems in Austria: New requirement as of 1 May 2016 at the earliest – Decision of the Constitutional Court
  • Austrian Ministry of Finance issues information on real estate transfer tax
  • Austrian Tax Facts and Figures

 

Issue 52, March 2016

  • Coming into force of Part II of the 2015 Tax Amendment Act
  • Update on Double Tax Treaties
  • Affiliated companies are not allowed to set up provisions for letters of comfort issued to other group companies
  • Update: Comprehensive administrative assistance arrangements regarding income tax law
  • Due diligence costs: Immediate deduction as operating expenses or capitalisation as acquisition costs?

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  • Salzburg Tax Dialogue 2015 – VAT
  • Annual update of the 2015 VAT guidelines
  • Austrian Tax Amendment Act 2015 – Customs-related innovations
  • Conclusions of the Salzburg Tax Dialogue 2015 on International Tax Law
  • Austrian Tax Facts and Figures

 


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