Oliver Karte

On 1 June 2022, the Austrian Ministry of Finance (MoF) issued a statement (EAS 3436), saying that it is changing its understanding of how certain IT services are qualified in the double tax treaty (DTT) with China.

Uncertainties relating to the determination of the profits attributable to a construction/installation permanent establishment (PE) are a substantial tax-related project risk for companies within the plant construction sector.