Martin Hummer

Based on the recent decision of the Austrian Financial Court, liability commissions must be charged from the start of the loan agreement, reductions in the Transfer Pricing with respect to deliveries of goods must be credibly demonstrated and the arm's length interest must be charged for supplier credits.

The new info from May 5, 2022 presents the current legal opinion of the Austrian tax author­ities with regard to bilateral MAP and AP.

Section 4 of the Austrian TP Documentation Law (VPDG) contains a notification obligation in connection with CbCR.