Potentially higher income tax burden through amendments to the Double Taxation Treaty between Austria and the United Arab Emirates

On 1 July 2021 Austria and the United Arab Emirates (UAE) have signed a protocol amending several key provisions of the Double Taxation Treaty. The most significant changes are made to Article 24 of the Double Tax Treaty. Currently this Article states that the double taxation of Austrian tax residents is avoided by exempting the […]

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New letter ruling on permanent establishments in the case of auxiliary activities within a company group

1 June 2021, the Austrian Ministry of Finance (MoF) published EAS (Express Answer Service) 3432. In this letter ruling, the MoF confirmed its previous view that there is only one set of circumstances in which activities, which by their nature constitute preparatory or auxiliary activities, do not lead to the creation of a permanent establishment […]

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BMF information on the application and interpretation of Double Tax Treaties

The COVID-19 pandemic has implications for the taxation of income of cross-border workers, as the allocation of taxation rights under tax treaties depends, among other things, on where the the activities are carried out. The duration of activities and the length of stay in a country are decisive factors for taxation and the creation of […]

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