Liechtenstein and Austria have signed a protocol to amend their double tax agreement, the Liechtenstein government has announced.
The agreement, signed by Liechtenstein Prime Minister Adrian Hasler and Austrian Finance Minister Hans Jörg Schelling on September 15, adjusts the the treaty’s article on the mutual agreement procedure to reflect the outcomes of the OECD/G20 base erosion profit shifting (BEPS) project, the Liechtenstein government said. Taxpayers applying for the mutual agreement procedure will no longer be required to apply in their state of residence; rather, they can apply in either state.
Further, an anti abuse provision is incorporated into the agreement to correspond with the BEPS minimum standards, Liechtenstein government said.
The agreement also addresses the taxation of public service employees.
Both countries have begun the processes necessary to bring the agreement into force. Once in force, the clarification on public service employees will begin January 1, 2015. The other changes will apply as of January 1, 2017.
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