Intra-group financing in Austria, alongside the interest rate, a particular strong focus is placed by the tax authorities on whether the debt instrument might be re-qualified into “hidden equity”. Thus, there should be documentation on the capital structure of the borrower, transparency of the loan agreement as well as the arm's length character of the terms and conditions.

In a recent decision, the Federal Fiscal Court (Bundesfinanzgericht, BFG) made important statements for M&A practice regarding a dividend reservation in favour of the seller in the course of a share deal. The reserved dividend was considered a tax-exempt profit distribution, and the criteria for this classification were elaborated on in more detail by the BFG.

As part of the Eco-Social Tax Reform 2022 (Ökosoziale Steuerreform 2022), the taxation of cryptocurrencies is included into the existing tax regime for capital assets. The Eco-Social Tax Reform 2022 was passed by the National Council on January 20, 2022 and published in the Federal Law Gazette on February 14, 2022.

This guide is the first comprehensive Private Clients study containing 26 country overviews providing cross-border assistance to private clients, corporate collectors, galleries, foundations and asset managers with regards to the taxation of artwork.

It remains unclear as to how the taxpayer can successfully request the granting of interest.

Due to the disagreement on a Europe-wide digital tax, about half of all European OECD countries have either announced, proposed, or implemented a digital services tax.