The operational functions of multinational companies (R&D, production, sales, services, etc.) are usually spread across multiple locations around the world. This presents considerable challenges for tax departments. This is because the tax regulations abroad often differ significantly from local tax legislation. Cross-border considerations must therefore go beyond the solutions that apply to individual sites.
Our WTS international tax law experts specialise in the management of cross-border projects. This is often required for mechanical and systems engineering, the IT industry, the service sector, as well as many other industries. All the while, the fiscal framework conditions in the project country and the ever-evolving international environment are key complexity drivers.
Our tax experts advise on the selection of organisational structures in the conflicting area between foreign subsidiaries and permanent establishments (PEs). In doing so, the recognition, registration and processing involved with PEs - also representative establishments under BEPS - is a frequent focus of our work.
WTS Austria also helps companies to fiscally optimise their foreign distribution models (authorised dealer, commission agent, representative, agent). Our range of services includes tax planning when structuring cross-border supply and service relationships within the group and selecting suitable foreign investment locations. We review existing corporate and investment structures (with respect to an exemption of dividend income and capital gains, loss utilisation in the group, avoidance of controlled foreign corporations tax, a reduction of withholding taxes, etc.) and identify alternatives for the group structure through the use of holding, license and financing companies.
In light of increasing digitisation, we are keeping an eye on current legal developments at OECD and EU level for the justification and taxation of so-called "virtual" or "digital premises". In addition, our international tax law team looks after inbound establishments of foreign companies in Austria and handles all compliance issues (including bookkeeping and payroll accounting).
At WTS Austria we provide companies with customised, practical and pragmatic solutions across all key legal areas during their projects and when founding a business establishment or subsidiary company. We provide support during audits, mutual agreement/arbitration proceedings, EAS inquiries and advance ruling queries (information notice as defined in Sec. 118 of the Austrian Fiscal Code (BAO)).
WTS Austria is also the ideal contact for tax interface advice in the fields of transfer pricing, VAT, customs, cross-border reorganisations and global expatriate services, for which we work closely together in integrated project teams. Through our integration in the WTS Global tax advisor network, which is represented in over 100 countries, we can implement projects quickly and efficiently and develop customised solutions.
We also represent international natural persons (from internationally active directors or board members to artists and athletes).
