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.

Since 1 January 2019, the refund of Austrian withholding taxes requires a mandatory electronic pre-application to be filed.

Since January 2019, a new double taxation treaty between Austria and Japan is applicable, replacing the former treaty dating back to 1961.

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.

On 23 October 2018, an amended double taxation treaty between Austria and the United Kingdom was concluded.

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 ...

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

Under current law, distributions made by corporations may be treated either as dividends or as a tax-neutral repayment of capital to the extent that sufficient paid-in capital exists despite being in the form of a dividend distributions.

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

The draft tax bill of the Tax Amendment Act 2015/2016 introduces an increase in the tax rate applicable to the investment income of individuals from 25% to 27.5%

With the amendment of the Austrian investment fund regime by virtue of including alternative investment funds into its scope, the tax aspects of re-qualifications of existing (private equity) vehicles into investment funds and thus the application of the Austrian investment fund tax regime were rather unclear.

The CJEU has confirmed that Austria is permitted to withhold tax refunds from foreign investment funds, provided that there is no discrimination on objective grounds and domestic funds are treated equally.

For many companies, bonus payments are an important instrument for employee retention and motivation.

On 16 June 2015, the Austrian government approved a draft bill of the Tax Reform Act of 2015/2016 for submission to Parliament.