How Will the IRS Know About My Foreign Account? Taxpayers who have financial assets outside the United States often ask the question “How will they (IRS) know about my Foreign Account?;” when they are considering how (or whether) to come clean and inform the IRS about their previously undisclosed foreign financial accounts…   LEARN MORE   Contributed by: Yiallourides & […]

AITC Newsletter October 2017


AITC Annual Conference 2017 held in Bucharest, Romania This year, the annual Meeting was held on 1st and 2nd September 2017 at one of the most distinguished venues in Bucharest, Romania – the Intercontinental Hotel. Our ever-growing family of professionals throughout the year has welcomed 8 new members from Bangladesh, Cyprus, Ghana, Mauritius, Papua New Guinea, Pakistan, Serbia and Turkey. […]

AITC Newsletter September 2017


Dear Clients, In November 2016, a new double tax treaty (DBA) was negotiated between Austria and Israel. This DBA relates to taxes on income and property tax and will replace the old agreement dating back to 1970. The old DBA of 1970 has made cross-border investments difficult, dividends and interest rates were disproportionately taxed in the country of origin. The […]

New double taxation agreement between Austria and Israel to come


Dear clients, Please find the tax newsletter July of our international network AITC. Best regards Manfred Gross Flat Tax: Italy opens its doors to the rich not residents The provision of Agenzia delle Entrate, 8th March 2017, operationalize the provision of Article 1, paragraph 152, of Law December 11, 2016, n. 232 (2017 Legge di Bilancio), which entered into Tuir […]

AITC Newsletter July 2017



The significance of a permanent establishment in international tax law Corporate profits are taxed in full in the state in which the company’s registered office is located. This basic principle also applies in cases where the company has international operations. However, there are a few exceptions to this principle, specifically where the company has a permanent establishment in another state. […]

The permanent establishment in international tax law


Dear Clients, Profit distributions from an Austrian subsidiary to its parent company are – under certain conditions – tax free. This means that the profit can be paid to the parent company in the EU without further tax deduction in Austria (capital gains tax = CGT). This CGT exemption for EU dividends in the sense of the “Parent-Subsidiary Directive” can […]

Profit distributions to EU parent companies (EU dividends)


AITC Tax Flash Editorial: The Future of Tax Sovereignty in the EU With the newest press release (discussed in the EU segment of November Edition) the Commission has opened up the old-new front (the idea has been present since 2003) regarding the unification of taxation of companies´ profits inside the EU in the form of the Common Consolidated Corporate Tax […]

AITC Tax Flash November 2016


AITC Tax Flash Editorial: The Problem of Retroactive Use of the Legislative Requalification of Tax Avoidance into Tax Evasion A flamboyant newspaper article title in the last week´s well circulated newspaper declared a famous football player as a tax evader. Naturally the title must have attracted the attention of any person who either knows this famous player or of the […]

AITC Tax Flash October 2016