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

  Dear Clients, On 1 August 2016 the Transfer Pricing Documentation Law was published in Austria. It applies to fiscal years starting on or after 1 January 2016. This law requires multinational companies, depending on their size, to prepare certain documents and files and to send them to the tax office. Documentation obligation Multinational companies must prepare a Country-by-Country report […]

Austrian Transfer Pricing Documentation Law 2016

Dear clients, Austrian tax inspectors and auditors from the Austrian social security authority are making a payroll audit in regular intervals. They are scrutinizing if the wage tax, social security and the payroll related taxes have been done properly. The audit period includes normally the (last) five years. What are the highlights the tax inspectors are going for? We have […]

Checklist Payroll – audit highlights of the tax inspectors

Dear clients, Foreign employees who are assigned to Austria are considered as Expatriates if they meet the following criteria: • the employee is an employee of a foreign company • the employee is assigned to an Austrian group-company of this foreign company • the employment in Austria must not exceed 5 years • the employee was not resident in Austria […]

New Expatriates Tax Regime in Austria