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  • Article

    Rechtspanorama – Ein Ende der Vergleichsgebühr!

    Im aktuellen Rechtspanorama spricht RAK-Vizepräsidentin Bettina Knötzl über die österreichische Vergleichsgebühr...
    AustriaTax
    KNOETZL HAUGENEDER NETAL Rechtsanwaelte GmbH
    KNOETZL HAUGENEDER NETAL Rechtsanwaelte GmbH
  • Article

    Ruling On Cross-Border Personnel Leasing Published

    Under double tax treaties that follow the OECD Model Convention, the remuneration for posted employees may be taxed both in the state of residence and in the state in which the employment is exercised.
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    Successful Appeal Regarding Taxation Of Foreign Interest Income

    On 26 February 2015, the Austrian Supreme Administrative Court decided in favor of an appeal filed by WOLF THEISS for a client who received tax exempt interest income from other countries.
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    EU-Wide System To Resolve Tax Disputes Between Member States Applies From 1 July 2019

    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.
    European UnionTax
    Schoenherr (Schönherr Rechtsanwälte)
    Schoenherr (Schönherr Rechtsanwälte)
  • Article

    An Apple A Day Keeps Taxation Away?

    The General Court (GC) of the European Union ruled in favour of Apple in the state aid case regarding Apple's Irish tax structure, annulling the 2016 decision of the European Commission (EC).
    AustriaTax
    Schoenherr (Schönherr Rechtsanwälte)
    Schoenherr (Schönherr Rechtsanwälte)
  • Article

    Austrian Ministry Of Finance On The Tax Treatment Of A Transparent Entity Under Italian Law

    The Austrian Ministry of Finance recently published guidance on the tax treatment of a participation in an Italian corporation that is deemed transparent from an Italian tax perspective.
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    Cross-border Home Office Set Ups In Austria – Tax Traps And PE Risk

    Remote work is here to stay, and so are the legal and tax challenges it brings. More and more international employees work remotely from Austria, temporarily or long term.
    AustriaTax
    GGI | Global Alliance
    GGI | Global Alliance
  • Article

    Interest Limitation Rule Of ATAD Not Implemented

    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.
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    Ministry Of Finance Issues Guidance On The Alienation Of A Partnership Stake In A Trilateral Setting

    From an Austrian point of view, partnerships are deemed to be transparent vehicles, meaning that capital gains emanating from the alienation are to be attributed to the German partners.
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    Ruling On Cross-Border Merger Involving An Austrian Real Estate Company

    This so called real estate or immovable property clause has been included in several newer Austrian double tax treaties.
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    First Arbitration Procedure Under A Double Tax Treaty Decided By The ECJ

    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).
    European UnionTax
    Wolf Theiss
    Wolf Theiss
  • Article

    Austrian Supreme Administrative Court on the Utlilization of Foreign Losses in Tax Treates with the Exemption Method

    AustriaTax
    Leitner & Leitner
    Leitner & Leitner
  • Article

    Ministry Of Finance Provides Guidance On Residence Certificates

    The Austrian Ministry of Finance recently summarized the cases where residence certificates issued on non-Austrian forms will be accepted.
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    Mutual Agreement Regarding The Frontier Worker Clause With Germany

    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 ...
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    Amended Treaty With The UK And New Treaty With Kosovo

    On 23 October 2018, an amended double taxation treaty between Austria and the United Kingdom was concluded.
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    Austrian Dividend Withholding Taxes Fully Refundable To Non-Resident Pension Funds

    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 ...
    AustriaTax
    DLA Piper UK LLP
    DLA Piper UK LLP
  • Article

    Constitutional Court Confirms Constitutionality Of Non-Deductibility Of Manager Remuneration Above EUR 500,000

    As of 1 March 2014, a restriction on the deductibility of manager remunerations for tax purposes exceeding EUR 500,000 per person and year was introduced in Austria.
    AustriaTax
    Schoenherr (Schönherr Rechtsanwälte)
    Schoenherr (Schönherr Rechtsanwälte)
  • Article

    Guidance On Taxation Of Bitcoins And Other Cryptocurrencies

    Recently, the Ministry of Finance published guidance on the Austrian income and value added tax aspects of investing in the crypto space.
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    New Legal Uncertainty On Treatment Of Interest Expenses Within Tax Groups

    The Federal Tax Court (Bundesfinanzgericht ) recently held that interest expenses incurred in connection with the acquisition of an affiliated company within a tax group are not tax-deductible.
    AustriaTax
    Wolf Theiss
    Wolf Theiss
  • Article

    Wolf Theiss International Tax Newsletter Austria & CEE

    We hope you enjoyed the holidays and are now curious to read the next issue of our International Tax Newsletter.
    WorldwideTax
    Wolf Theiss
    Wolf Theiss

Showing 21–40 of 106 results

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