Tax & Legal

In a most current circular, the Federal Ministry of Finance (MoF) comments on the disclosure of tax administration acts by making them available for data retrieval effective 1 January 2026, as well as on legal issues concerning the application of the revised version of Section 122a of the General Tax Code.

In order to determine the content of an administrative act, the declared intention of the authority must be taken into account and not the literal meaning of the relevant wording; however, a notice clearly addressed to a specific addressee is not open to interpretation in this respect. This was decided by the Supreme Tax Court in a decision published on 8 April 2021.