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11 July 2019

Until now, the Austrian Federal Ministry of Finance (BMF) has specifically denied the permanent establishment status of a domestic home office of an employee of a foreign entity based on para. 12 in the Commentary to Art. 5 of the 2017 OECD Model Tax Convention (the “OECD Model”), if his or her...

25 August 2017

Like in Austria most countries which operate Country by Country Reports (CbCR) require a notification referencing the entity of the group that files the CbCR. This is also applicable for UK entities and the deadline ends on the later of 1 September 2017 and the end of the accounting period in...

23 February 2017

On November 4th, 2016 the German Bundesrat adopted a capital transfer tax reform, which took effect retroactively on July 1st, 2016. This resulted in a large number of tax-advantaged transfer processes prior to the entry into force of the new law. In this respect it needs to be noted that gifts...

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