PwC Austrian Tax News Archiv 2006

Issue 9, December 2006

• Recent transfer pricing deve-lopments in the pharmaceutical industry
• Bulgaria and Romania to join EU on 1 January 2007
• “Undisclosed factoring” within the group
• Silent partnership
• DTA Austria – Sweden
• Black funds – How to avoid lump-sum taxation
• Important changes to the VAT Guidelines
• Income tax on speculative gain arising from sale of home abroad
• Specific tax privilege also for employees of Swiss companies
  
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• New filing regulations for Financial Statements as at 31 December 2007 and increase of fines starting from 1 July 2006
• Interesting opportunities for investors provided by Austrian DTAs
• A modest home can create a residence for income tax purposes in Austria
• Stamp Duties
• VAT fraud – Carousels and Missing Traders
• Harmonization of Travel Expenses across the Corporate Group
• Compulsory Registration of Foreign Company Car in Austria – Possible Violation of EC-Law
• International Assignments – Applicability of Austrian Labor Law
• Transaction costs in a share deal
  
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• New law to support middle market
• Draft Protocol for amendments of the Tax Treaty between Austria and Slovenia
• Taxation of foreign investment funds and life insurances
• Electronic filing – the direct line to the Austrian authorities
• Entertainment expenses and company cars
• New reporting requirement for cross-border services as of 1 January 2006
• International assignment of employees between group companies and the interpretation of “international employer”
  
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• Recent developments in the international law as of 1 January 2006 for Austria
• Indirect taxes on energy and refund of these taxes
• Stamp duties and transfer taxes
• News in Austrian VAT law
• New regulation on the squeeze out of minority shareholders
• Share purchase programs and stock option plans under the new Capital Markets Act
• International taxation of Supervisory Board members of a stock corporation or company with limited liability in Austria
  
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• Acquisitions in Austria – double-dip structures
• Release of partially valuable debt by shareholders does not increase tax profit
• Dividend taxation of non-resident corporations in Austria is discriminatory according to the EC Treaty
• New Administrative High Court ruling on the “Mantelkauf”
• Outbound dividends and withholding tax
• Austrian real estate – amendments to taxation of non-residents
• Stock option plans in Austria
• Capital tax on indirect equity contributions
• Revision of the Double Tax Treaty between Austria and Switzerland
  
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• Austrian Supreme Administrative Court ruling on finance base companies
• The European company (SE) - taxation and structuring models
• Management, a “risky job”: Measures to reduce the risks
• Remuneration of Austrian managing directors of a company with limited liability (“GmbH”): Less is more
• Asset deal vs share deal – Austrian tax aspects
  
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