Austria Tax News
OECD Council approves 2008 Model Tax Convention
Treaty between Chile and Austria – negotiations
Treaty between Austria and Argentina terminated
Protocol to treaty between Poland and Austria approved by Polish parliament
Comments on draft contents of 2008 update to Model Tax Convention published
ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details
ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment
Treaty between Austria and Denmark – details
ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends
European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case
Treaty between Turkey and Austria signed
European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax
ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law
Protocol to treaty between Poland and Austria signed
European Commission takes steps against Germany, Estonia and Czech Republic regarding taxation of outbound dividends
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details
European Commission takes steps against Belgium for failure to adopt implementing measures of Merger Directive
Treaty between Denmark and Austria ratified
ECJ: Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital – details
European Commission issues communication regarding accession of Bulgaria and Romania to Arbitration Convention
OECD released discussion draft on transactional profit methods
ECJ: Advocate General finds the 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
Protocol to theaty with Austria enters into force
Details of the first-time income and capital tax treaty between Austria and Saudi Arabia, signed on 18 March 2006, have become available. The treaty was concluded in the German, English and Arabian languages, each text having equal authenticity. In the case of divergence, however, the English text prevails. The treaty generally follows the OECD Model Convention.
Treaty between Denmark and Austria – bill reintroduced
Treaty between France and Australia submitted to French Parliament
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