Austria updates transfer pricing guidelines
An update on Austrian transfer pricing rules was made on the 7th October 2021. Details are here. ... - Continue reading
Category: Austria
Austria to Introduce Tax on Tech Giants With Annual Revenues Over $864Mln – Kurz
VIENNA (Sputnik) – The Austrian government will introduce a 3-percent tax on international tech giants with an annual turnover exceeding 750 million euros ($864 million), Austrian Chancellor Sebastian Kurz said on Thursday. “Europe currently does not have taxation of digital Internet giants and Austria intends to become a pioneer in… – Continue reading
Worldwide: UK Tax Round Up – November 2018
General UK Tax Developments Finance Bill The Finance (No 3) Bill 2018-19 (which will become the Finance Act 2019) was published on 7 November and includes legislation to enact the changes highlighted in our UK Budget blog post ( UK Budget Blog). Another key area covered by the Finance Bill… – Continue reading
PenSam to step up scrutiny of partners as €55bn tax scandal unfolds
The head of one of Denmark’s biggest pension funds has spoken out to condemn a wide-scale tax fraud uncovered by a media investigation. Danish national broadcaster DR, newspaper Politiken and other European media outlets in the last three months have published articles detailing a withholding tax scam – dubbed ‘Cum-Ex’… – Continue reading
Swiss Come Clean Amid Data Swaps
Switzerland’s abandonment of banking secrecy for international tax dodgers is having an unexpected side effect at home: more domestic tax cheats with accounts around Europe are coming forward. If 2017 was the glide path for Switzerland’s international data-swapping agreements, this year means business: Swiss banks must automatically share client data… – Continue reading
EU Seeks a Digital Tax to Stem the ‘Bags of Money’ Lost to Loopholes
Finance ministers discuss new tax plans in Tallinn, Estonia France’s Le Maire says EU citizens ‘outraged’ by situation European Union finance ministers are developing a new way to tax digital companies such as Amazon.com Inc. and Facebook Inc. to raise money from an industry that they say provides less than… – Continue reading
Austrian finance minister: fighting tax evasion will be EC presidency priority
ZURICH (Reuters) – Pushing forward European and international measures to prevent profit shifting and international tax fraud will be a top priority for Austria’s European Council presidency in the second half of 2018, Austrian Finance Minister Hans Joerg Schelling said on Saturday. “The cross-border fight against tax fraud and tax… – Continue reading
Austria Seeks Tax Agreement with Iran
In a meeting with Iran’s foreign minister in Tehran on Sunday, Schelling said he has visited Iran with the purpose of boosting bilateral economic and financial relations. Voicing Austria’s eagerness to develop joint training programs with Iran in the banking industry, Schelling hoped he would nail down investment deals and… – Continue reading
ECJ Rules In Austria’s Favor In Tax Dispute With Germany
The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax… – Continue reading
Protocol signed between India and Austria to curb tax evasion
For avoiding double taxation and for the prevention of fiscal evasion with respect to taxes on income, India and Austria signed a protocol, amending the existing convention between the two countries. On behalf of India, the protocol was signed by the Chairman of CBDT, Shri Sushil Chandra, and on behalf… – Continue reading
Austria: Ministry Of Finance Issues Guidance On The Alienation Of A Partnership Stake In A Trilateral Setting
On 29 October 2016, the Austrian Ministry of Finance provided interesting guidance on the tax consequences of an alienation of a participation in a Hungarian partner- ship by an Austrian partnership consisting of German partners. The case revolved around an operative Austrian partnership (GmbH & Co KG) with German resident… – Continue reading
Belize Financial Regulator Warns Against Fraudulent Bitcoin Investment Company
The financial regulator of Central American nation Belize has issued a public warning against XMAXBIT, a company that claims to provide returns for investors by investing in cryptocurrencies like bitcoin. Published on Monday, the Office of the International Financial Services Commission (IFSC), Belize’s financial regulator, has warned users against dealing… – Continue reading
Switzerland, Austria To Terminate WHT Agreement
The withholding tax (WHT) agreement between Switzerland and Austria will be terminated on January 1, 2017, when the agreement between Switzerland and the EU on the automatic exchange of tax information enters into force. On November 11, 2016, Switzerland and Austria signed an agreement to ensure a smooth transition between… – Continue reading
Country-by-Country Confusion: Narrow BEPS Queries Abound
Global governments battling tax avoidance increasingly are pushing multinational corporations for a bigger picture of how and where they pay taxes, leading to increasingly narrow questions from company tax officers. “We have a number of entities that are disregarded for U.S. tax purposes. When I fill out the country-by-country form,… – Continue reading
Japan, Austria Agree MAP Arbitration
The Governments of Japan and Austria have agreed in principle to amend their double taxation avoidance agreement to further promote trade and investment between the two countries. The new agreement would enable arbitration under the mutual agreement procedure to ensure settlement of double tax disputes. The new agreement will also… – Continue reading
Germany and Panama move closer towards information-sharing agreement
Talks on a data exchange agreement have progressed following Panama President Varela’s state visit to Berlin. Panama is looking to clean up its reputation in the aftermath of the “Panama Papers” leak earlier this year. Germany and Panama moved a step closer towards signing an information-sharing agreement, German Chancellor Angela… – Continue reading
Ukraine and Luxembourg sign a Protocol modifying their double tax treaty
On 30 September 2016 Ukraine signed a protocol (the “Protocol”) modifying the not-yet-in-force Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital (the “Convention”)…. – Continue reading
German taxman goes after foreign banks
German state prosecutors are investigating nearly 60 foreign banks for “abetting tax evasion,” a newspaper report has said. Self-declaring former tax-evaders are proving a particularly valuable source of information. Prosecutors in Germany’s most populous state are investigating 57 foreign banks on charges of abetting tax evasion, according to the “Süddeutsche… – Continue reading
EU countries eye potential share of Apple windfall
Potential slice of the Apple pie stems from Commission’s invitation to EU tax authorities. BRATISLAVA — The €13 billion clawback of unpaid taxes from U.S. tech giant Apple has piqued the interests of EU finance ministers, who have today asked the European Commission for more details on the potential share… – Continue reading
Ukraine, Austria Increase DTA Withholding Tax Rates
Ukraine and Austria have agreed to sign a protocol to their double taxation agreement to increase withholding tax rates on dividends, interest, and royalty income. The protocol increases the withholding tax rate for dividends and interest to 15 percent and five percent, respectively. Additionally, the royalty rate for patents, trademarks,… – Continue reading
Canada willingly makes tax deals with tax havens
The seeds of Canadian corporations hiding billions of dollars in offshore tax havens were sown more than 40 years ago, after the Canadian government pursued a series of tax treaties with tiny Caribbean and European nations. The 92 tax treaties now signed with countries such as Barbados, Jamaica and Malta… – Continue reading
Troubling Implications of the BEPS Project: Interest Deductibility
On October 5, 2015, the Organization for Economic Cooperation and Development (OECD) issued final tax policy recommendations stemming from its Base Erosion and Profit Shifting (BEPS) project. The reports, endorsed by the G20 Finance Ministers on October 8 and by the G20 leaders at their November 15-16 summit, consist primarily… – Continue reading
Would the real tax havens please stand
“It is tantamount to an economic blockade”. That’s how Antigua and Barbuda’s Prime Minister, Gaston Browne, described the current withdrawal from Caribbean indigenous and offshore banks of correspondent relationships by US banks. His sentiments were echoed by Dean Barrow and Freundel Stuart, the prime ministers of Belize and Barbados respectively…. – Continue reading
The ‘extraordinary’ loophole that saw Russia threaten to brand UK as tax haven
Russia has come close to blacklisting the UK as a tax haven as concerns grow over Scotland’s booming offshore business. The Kremlin’s Finance Ministry had announced that it would officially equate Britain with traditional “fiscal paradises” like Panama, the British Virgin Islands and the Caymans. Such a humiliating move would… – Continue reading
Avoiding tax traps: don’t forget about non-competition agreements
Non-competition agreements can be a valuable tool for purchasers who want to protect their investments in new businesses. However, non-competition agreements can have unintended and unexpected tax consequences, particularly to sellers who grant non-competition agreements to purchasers. The Income Tax Act (Canada) (the Act) contains specific provisions regarding the taxation… – Continue reading
10 biggest multinational offenders evading taxes in the UK
The brands are known worldwide, and even though global companies like Google, Amazon, and Starbucks make billions — they pay little or no taxes at all in the UK and other markets where the firms make a majority of revenue and profits. Companies like Microsoft, Twitter, and Apple don’t set… – Continue reading
Tanzania: Managing Tax Risks – Double Tax Treaties and Implications
Can tax treaty provisions override domestic law?In our last article we defined double taxation as an exposure to tax more than once on the same profit or income. We also highlighted the two types of double taxation i.e. economic double taxation and juridical double taxation and also noted that a… – Continue reading
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading
Tanzania: Managing Tax Risks – Double Tax Treaties and Implications to Undertakings of Multinationals
The term double taxation refers to an exposure to tax more than once on the same profit or income. There are two types of double taxation i.e. economic double taxation and juridical double taxation. Economic double taxation is broad and occurs in a situation where an amount of income is… – Continue reading
Ireland Issues Brief On EU Savings Taxation
The Irish Revenue has released a new brief detailing the impact on Irish paying agents of the European Union’s decision to replace the Savings Tax Directive with legislation providing for the automatic exchange of tax information. On November 10, the European Council repealed Directive 2003/48/EC on the taxation of savings… – Continue reading
Cabinet reviews key issues
(MENAFN – Arab News) RIYADH: Custodian of the Two Holy Mosques King Salman on Monday briefed the Cabinet over the phone call he received from the king of Bahrain the call he made to the president of Nigeria and the results of his talks with the chairman of the Presidency… – Continue reading
Spain and Finland sign new treaty to avoid double taxation and to fight tax fraud
Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading
Ireland: Common Reporting Standard (CRS) Update
The common reporting standard framework was first released by the Organisation for Economic Co-operation and Development (the “OECD”) in February 2014 as a result of significant political will demonstrated by the G20 members to endorse a global model of automatic exchange of information and increase international tax transparency. On 21… – Continue reading
IP BOX: Italian and European Legal Framework
On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading
Corporate taxation proposals: Malta ‘breaks silence on reservations’
Finance Minister Edward Scicluna pushes for ‘flexibility’ during today’s meeting of EU finance ministers in Brussels Malta has come out strongly against applying “rigid rules”, urging the European Commission to adopt a more flexible approach as it drafts legislation on taxation. Corporate tax was high on the agenda of EU… – Continue reading
Doesn’t Look Like Much Has Really Changed At Deutsche Bank
Barely a week goes by without Deutsche Bank featuring in the news for some reason, usually a bad one. This time, it’s tax avoidance. The FT reports that Deutsche Bank “has been devising complex tax avoidance strategies for some of its largest corporate clients”. Not that this is illegal, of… – Continue reading
Interim tax in connection with non-resident beneficiaries
Introduction Facts Decision Introduction The European Court of Justice (ECJ) recently ruled that the system of interim taxation for Austrian private foundations does not comply with EU law.(1) A special feature of private foundations is the so-called ‘interim tax’ – a type of corporate income tax. Pursuant to Section 13(3)… – Continue reading
A Delicate Balance: Tax Competition Versus Cooperation
Tax administrators want to maximise the amount of revenue collected without stifling the county’s competitiveness as a business destination. How should ASEAN countries navigate changing international conditions to meet this goal? By Rebecca Tan – As Benjamin Franklin once famously said, “In this world, nothing can be said to be… – Continue reading
EU Savings Directive repealed
On November 10th 2015, the European Council announced that the EU Savings Directive 2003/48/EC (EUSD) has been repealed in order to eliminate the overlap with other legislation developed in the aspect of preventing measures of tax evasion. Brief Background The 2003 EUSD, which originally came into effect on 1 July… – Continue reading
AUSTRIA: COMMON REPORTING STANDARD IMPLEMENTATION
Austria’s legislative implementation of the common reporting standard (CRS) requires the exchange of information beginning in 2018 (instead of 2017 as in most EU Member States). DUE DILIGENCE Austria has voluntarily agreed to apply the new financial account “due diligence” requirement for accounts opened on or after 1 October 2016,… – Continue reading
France wants financial transactions tax accord in Brussels
France wants an agreement on a financial transactions tax (FTT) struck on Monday after a meeting of euro zone finance ministers, Finance Minister Michel Sapin said, reports Reuters. “We have done most of the technical work. I think the time has come to make a decision,” Sapin told reporters. “We… – Continue reading
Mexico’s 16% Discount for Paying Cash Shows Tax Evasion’s Allure
On a warm afternoon last month, Mexican central bank Governor Agustin Carstens looked out over sun-drenched piles of dirt and construction equipment near Guadalajara and hailed the groundbreaking of a new currency-printing plant as a sign of a solid economy. There’s one catalyst for rising cash demand that isn’t a… – Continue reading
India: Procurement Services By Chinese Company Taxable As Fees For Technical Services Under India-China Tax Treaty: AAR
There can be no straight jacket formula to determine what is meant by “provision of service,” which may include where services are i) provided; ii) rendered; or iii) utilized. The expression ‘provision of services’ is much wider than ‘provision of rendering of services,’ and covers the services even if they… – Continue reading
Comes to Switzerland on tax havens list?
Switzerland stands on a provisional Russian tax havens list: The document lists 119 countries and territories which do not ensure the exchange of tax information with Russia Russian authorities consider. If the document actually come into force as planned in the form of a regulation, threaten Russian investors in Switzerland… – Continue reading
Russia Wants to Put Austria on Tax Haven List
Austria is on the preliminary list of 119 countries and territories which from the point of view of Russian authorities don’t guarantee the exchange of tax information with Russia. If the document is implemented, as planned, in form of a resolution, Russian investors in Austria will face massive tax disadvantages… – Continue reading
Agreements with Italy and Japan to avoid international double taxation
The negotiations conducted by the Ministry of Finance and the Internal Revenue Service (SII) for Chile to sign the agreements to avoid international double taxation with Italy and Japan have concluded successfully. “The successful completion of negotiations with two of the world’s major economies crown an exceptional year in strengthening… – Continue reading
Tax Justice for Social Justice
By Martina Neuwirth and Thomas Kattnig [This blog article published on July 9, 2015 is translated from the German on the Internet, http://blog.arbeit-wirtschaft.at.] June 23 was the international day of public services. Did you know that? Provision of these services – water, hospitals, schools, culture, energy, streets, public transportation and… – Continue reading
India: No MAT for FIIs/FPIs For Period Pprior To April 2015
The CBDT has clarified that MAT provisions will not be applicable to those FIIs /FPIs which do not have a permanent establishment in India, for the period prior to 1 April 2015. An amendment to the IT Act will be made in the winter session of Parliament and directions have… – Continue reading
