Austria–MNE Tax

Austria

Recent corporate tax trends in EU countries: Cristina Enache / Tax Foundation→

April 5, 2022

Asia-Pacific

Significant changes to the income tax treaty between Austria and the UAE as of 2023

March 24, 2022

Iris Burgstaller and Fanni Deak, TPA Austria, discuss recent changes to the Austria-United Arab Emirates income tax treaty to implement the OECD standards on base erosion and profit shifting (BEPS); after the exchange of the instruments of ratification, the amendments will be applicable for tax years after December 31, 2022.

Austria

EU’s path forward on global minimum tax is under debate

January 18, 2022

EU member states are at odds on various issues related to the directive to implement within the EU the global minimum tax portion of the OECD agreement, with several members expressing concerns about key aspects in a January 17 Economic and Financial Affairs Council . . .

Africa

OECD updates and expands transfer pricing country profiles

December 13, 2021

The OECD today released updated transfer pricing country profiles for 21 countries, including three countries for which it has not previously published profiles: Albania, Kenya, and . . .

Americas

India and US agree on transition from India’s ‘equalization levy’ digital tax

November 29, 2021

The US and India have reached a compromise on a transition from India’s “equalization levy” digital services tax towards the terms of the October 8 multilateral agreement on new international taxing rules, according to a November 24 . . .

Asia-Pacific

Turkey and US agree on phase-out of digital tax

November 23, 2021

The US Treasury announced on November 22 that it has reached an agreement with the Turkish government on Turkey’s transition from its digital services tax to the new taxing rules under the . . .

Accounting

European digital services taxes to stay for now, with offsetting credits, countries agree

October 21, 2021

Under an October 21 agreement between the United States and Austria, France, Italy, Spain, and the UK, the European countries can keep their existing digital services taxes in place pending implementation of Pillar 1 of the OECD global tax deal; however, multinational groups . . .

Austria

Austria updates transfer pricing guidelines

October 13, 2021

Iris Burgstaller, TPA Austria and Baker Tilly, discusses the Austrian Ministry of Finance’s October 7 publication of the final version of the revised Austrian transfer pricing guidelines, replacing the 2010 guidelines to incorporate OECD developments, particularly the . . .

Americas

ICAP multilateral tax risk assurance program applications due September 30

September 2, 2021

Multinational entities interested in participating in the first full round of the OECD Forum on Tax Administration (FTA) International Compliance Assurance Programme (ICAP) have until September 30 to submit the . . .

Asia-Pacific

Russia’s new double tax treaty policy: the score is 3 to 1

August 4, 2021

Roustam Vakhitov, Crowe Expertiza, analyzes Russia’s new tax treaty policy following the government’s June 7 notice to the Dutch government of Russia’s intent to terminate the double tax treaty between the two countries after a failure to . . .

Austria

How will the European Commission define shell companies to stop tax avoidance?

June 7, 2021

New York City Economist Dr. J. Harold McClure discusses the European Commission’s launch on May 20 of an initiative to address the use of shell companies in international arrangements . . .

Americas

US plans tariffs against six nations as digital tax talks heat up

June 2, 2021

The US Trade Representative on June 2 announced and then immediately delayed implementation of new tariffs on goods from six countries – Austria, India, Italy, Spain, Turkey, and the UK – in response to . . .

Austria

EU reaches agreement on public country-by-country tax reporting

June 2, 2021

Negotiating teams from the European Council and European Parliament reached an agreement on June 1 on a proposed directive that would require public disclosure of country-by-country tax information by certain . . .

Austria

ECJ rules interest payments due for untimely value-added tax refunds

May 19, 2021

The European Court of Justice ruled on May 12 that refunds resulting from adjustments to the amount of value-added tax that a taxpayer owes must be paid with interest when not paid within a reasonable period of time . . .

Americas

US threatens tariffs against six more nations over digital taxes, drops investigation into others

March 29, 2021

The US Trade Representative has recommended trade actions against Austria, India, Italy, Spain, Turkey, and the UK following its findings that digital services taxes adopted by these countries discriminate against US companies. . .

Austria

Trade groups sue over Maryland’s controversial tax on digital advertising

February 22, 2021

Four organizations have joined in a lawsuit challenging a new Maryland state law levying a tax on digital ad revenue – the latest twist in an ongoing dispute with international implications. The US Chamber of Commerce, the . . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021

Americas

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others

January 15, 2021

Digital services taxes enacted in Austria, Spain, and the UK discriminate against US companies within the meaning of Section 301 of the US Trade Act of 1974, the Office of the US Trade Representative . . .

Americas

US says Italy, India, Turkey digital services taxes are discriminatory, suspends France tariff action

January 7, 2021

Digital services taxes enacted in India, Italy, and Turkey discriminate against the United States; however, for now, no trade actions will be taken, the Office of the US Trade Representative . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Americas

US to investigate digital services taxes in India, Brazil, Turkey, Indonesia, the European Union, five EU countries

June 2, 2020

The Office of the US Trade Representative (USTR) today announced that it has initiated an investigation into digital services taxes proposed or adopted in . . .

Austria

Austria suspends deadlines for proceedings relating to tax offences to May: Federal Ministry Republic of Austria Finance→

April 14, 2020

Austria

OECD publishes reports on cross-border tax dispute resolution Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden

April 10, 2020

The OECD on April 9 published stage 2 reports approved by the “Inclusive Framework on BEPS,” an OECD-led body of 135+ countries, that assess the cross border tax dispute resolution procedures . . .

Austria

Austria objects to German proposal to exclude from financial transaction tax derivatives and other speculative instruments making deal among 10 EU states less likely: The Associated Press / The New York Times→

February 4, 2020

Austria

Germany, France, Italy, seven others, supporting plan for EU tax on stock trades of a minimum of .2% of transaction value: Patricia Kowsmann / Wall Street Journal→

December 11, 2019

Americas

US trade officials propose tariffs of up to 100 percent on French goods to counter digital services tax

December 2, 2019

The office of the United States Trade Representative (USTR) today proposed retaliatory tariffs of up to 100 percent on French wine, cheese, handbags, makeup, china, and similar items, after concluding that France’s digital services tax . . .

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Austria

EU loss in Polish State aid case may be a win for digital services tax

May 17, 2019

Leopoldo Parada of the University of Turin, Italy, discusses a May 16 EU General Court decision in Poland v. Commission which could have implications for the legality, under EU State aid rules, of unilateral European digital services tax measures . . . .

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

Americas

US formally asks the EU to “ditch” digital tax

October 22, 2018

Alan Rhode, co-founder of Taxmen.eu, discusses a US Senate Finance Committee letter, released last week, challenging the EU digital services tax, as well the latest positions of EU countries on the controversial proposal . . .

Austria

Kerim Keser joins Duff & Phelps’ European transfer pricing practice

June 13, 2018

Kerim Keser is the new head of Duff & Phelps’ German, Swiss, and Austrian transfer pricing practice, the firm announced . . .

Austria to seek consensus on digital tax during EU presidency: The Irish Times→

July 18, 2018

Austria

Austria planning digital tax, finance minister says: Irish Times→

January 2, 2019

More: France 24, Seeking Alpha.

Asia-Pacific

US, Austria sign agreement to exchange country-by-country reports on multinationals

August 24, 2018

The US and Austria have signed a competent authority agreement to exchange country-by-country reports on multinationals operating in their countries, US Treasury . . .

Asia-Pacific

India, Austria tax treaty protocol signed

February 7, 2017

Indian and Austrian government officials on February 6 signed a protocol to their 1999 tax treaty that would broaden the scope of the countries’ existing framework of exchange of tax. . . .

Asia-Pacific

Multilateral tax treaty enters into force in Singapore affecting 14 bilateral treaties

April 1, 2019

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered . . .

Austria

Front-running Austrian conservatives advocate MNE tax avoidance crackdown: Reuters→

August 30, 2017

EU Court rules in favor of Austria in tax dispute with Germany concerning profit-participation certificates

April 27, 2017

The European Court of Justice has today ruled in Austria’s favor a dispute between Austria and Germany (Case C-648/15) concerning which country can tax interest from profit-participation certificates (Genussscheine) received by an Austrian. . .

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin