12. April 2021 Determination of the addressee of a tax audit notification o ... 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. Kategorien: Supreme Tax Court casesSchlagwörter: administrative principles, suspension of ...
28. November 2017 Limited taxpayers: withholding tax on cross-border licensing ... At the beginning of November 2017 the Federal Finance Ministry published the long-awaited circular on its intended application of the rules (Section 50a Income Tax Act)applying to limited taxpayers and withholding tax on cross-border licensing of software and databanks. Kategorien: Official PronouncementsSchlagwörter: International Tax, administrative princi ...
01. Januar 2017 Administration publishes regulations on branch profits On December 22, 2016 the finance ministry has finally published its detailed administrative principles on the allocation of profits between a business and its foreign branches. Kategorien: Official PronouncementsSchlagwörter: permanent establishment, branch, AOA, ad ...