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Home Locations Austria | ICON Wirtschaftstreuhand GmbH

WTS in Austria | ICON Wirtschaftstreuhand GmbH

Europe

Linz
Linz
ICON Wirtschaftstreuhand GmbH
Stahlstraße 14
4020 Linz
http://www.icon.at
+43 732 694126990
matthias.mitterlehner@
icon.at

One of our local partner firms is ICON.

Over the last 25 years ICON has developed a renowned reputation for providing personalized high-quality tax services in Austria, with a particular focus on international tax law matters.

Our wide-range service portfolio comprises all-in-one solutions and tailor-made solutions based on the very specific client needs.

ICON´s core competencies include: International Tax, Corporate Tax, M&A, Indirect Tax & Customs, Transfer Pricing, Private Clients, Tax Controversy, Global Employment Services and Auditing.

Our clients mainly compose of industrial enterprises acting worldwide, machinery and plant manufacturers and construction companies, medium-sized enterprises and other tax advisors seeking specific advice on various tax matters.

ICON currently employs more than 75 passionate people, whereof 22 are qualified tax advisors.

Awards

  • 2019 Austria Tax Firm of the Year I International Tax Review
  • 2019 Tax Advisor of the Year in the category M&A I DiePresse & ifa AG
  • 2018 Austria Tax Firm of the Year I International Tax Review
  • 2018 Tax Advisor of the Year – Allrounder-Upper Austria I DiePresse & ifa AG
  • 2015 Tax Advisor of the Year in the category International Tax Law I DiePresse & ifa AG

 

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Main Contact
Mag. Matthias Mitterlehner
Partner
WTS Global International Corporate Tax GSL Co-Head & Europe Regional Leader
Austria | ICON Wirtschaftstreuhand GmbH, Austria
http://www.icon.at
+43 732 694126990
View Profile

ICON´s News

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.

Decision of the Austrian Financial Court regarding Transfer Pricing
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On November 15, 2022 the Austrian Ministry of Finance (MoF) published an information letter on the attribution of dividends for income tax purposes. The letter follows the decision of the Austrian Supreme Administrative Court concerning short-term Cum-Ex-Trades and withholding tax refunds.

Consequences of the Cum-Ex-Trades on WHT refund and relief in Austria
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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.

Austria: Double taxation risk in connection with software as a service
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The Austrian tax reform 2022 (Abgabenänderungsgesetz 2022 –AbgÄG 2022) brings various changes to the taxation of investment income.

Changes in the taxation of investment income by way of the Austrian tax reform 2022
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The new info from May 5, 2022 presents the current legal opinion of the Austrian tax author­ities with regard to bilateral MAP and AP.

New Info from the Austrian Ministry of Finance – Mutual Agreement Procedure and Arbitration Procedure
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In a legal opinion, the “BMF” has explained under which circumstances a permanent establishment is triggered by home office activities.

Austria: Establishment of a PE through home office activity
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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.

India and Austria: International project business – India: Tax trap offshore supplies 
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The Austrian VAT regulations (§ 3 (8a) VAT Law) give an example of how to correctly handle such distance sales of imported goods, which has been adapted to the customs provisions

Austria: Customs law thwarts VAT law
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Section 4 of the Austrian TP Documentation Law (VPDG) contains a notification obligation in connection with CbCR.

Austria: No annual CbCR notification required since 1 January 2022
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In its decision of 13 January 2021 (Ro 2018/13/0003), the Austrian Supreme Administrative Court decides the question whether a US Trust is eligible for withholding tax refund on Austrian profit distributions.

Austria: Supreme Administrative Court on foreign Trusts
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Austria is facing new regulatory requirements because of a recent ECJ decision which has led to a new treatment of rental turnover of foreign investors.

Austria: Change in the VAT treatment of rental revenues of foreign property owners
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At the beginning of November 2021, the Austrian Ministry of Finance published a draft bill on the eco-social tax reform 2022 which includes new rules for the taxation of income from crypto currencies.

Draft bill on new Austrian tax regime for crypto currencies published
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On 7 October 2021, the Austrian Federal Ministry of Finance published the final version of the Austrian Transfer Pricing Guidelines (Austrian Guidelines 2021). In 2010, the Austrian tax authorities published the transfer pricing guidelines based on the OECD Guidelines from 2010 for the first time.

New Austrian Transfer Pricing Guidelines 2021
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The Austrian Federal Court has recently ruled that crypto mining cannot be deemed as an economic activity for VAT purposes.

Tax treatment of crypto mining in Austria
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It remains unclear as to how the taxpayer can successfully request the granting of interest.

Austria: Higher court confirms the granting of interest for overdue VAT credits
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VAT exemption for the management of special investment funds – Services provided by a third party – CJEU joined cases C-58/20, K and C-59/20, DBKAG, dated 17 June 2021.

Austria: New CJEU decision on VAT Exemption
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The Austrian Administrative Supreme Court (Verwaltungsgerichtshof) had to deal with a trademark licensing between Malta and Austria. The Austrian trading company MCo had demerged its business and real estate to the Austrian company XCo in 2007. The trademarks stayed with MCo.

Austrian Supreme Administrative Court on beneficial ownership of trademarks
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In Austria, the draft of the revised Austrian Transfer Pricing Guidelines 2020 was published. Our Austrian colleagues outline the changes and consequences.

New Austrian Transfer Pricing Guidelines 2020
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Limitations on the refund of withholding tax on leasing of personnel remunerations

Austria: Administrative Supreme Court limits withholding tax refund on leasing of personnel remunerations
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Austria made a U-turn and abolished the wage withholding tax for foreign employers just introduced at the start of last year.

Austria: Wage withholding tax for foreign employers abolished!
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The Austrian tax administration takes a “facts and circumstances-approach” to assess whether home office work creates a permanent establishment (PE) for the foreign employer.

Home Office work in Austria and consequences due to Covid-19
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An overview of measures introduced in implementation of the EU directive on tax dispute resolution mechanisms.

Austria: Implementation of the EU Directive on Tax Dispute Resolution Mechanisms
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Section 48 of the Federal Fiscal Code (BAO) allowed for the unilateral elimination of international double taxation

Autria: Limits of temporary relief in the MAP (Mutual Agreement Procedure)
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Regarding the measures planned for 2019, a bill has been filed in early July 2019 and a decision of the national assembly is expected in September

Austrian Tax Reform 2019/2020
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The relevant regulations that foreign companies have to comply with in Austria are regulated in the “Wage and Social Dumping Control Act”

Reporting and documentation obligations for employee secondments to Austria
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The monitoring will be evaluated on an ongoing basis and on 31 December 2024 an evaluation report will be presented

Austria: Horizontal monitoring
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The Express Answer Service (EAS) offers taxpayers the opportunity to post questions of interpretation regarding international tax matters to the MoF

Construction PE – Austrian MoF on influence of trial runs and subcontracting
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Since 1.1.2019 applicants for refund of Austrian withholding taxes have been obliged to use an electronic pre-application

Withholding taxes: new formalities for refund of Austrian WHT
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From July 1, 2019 the advance ruling must be issued within two months of the application being submitted. 

Austria: The expanded Advance Tax Ruling Procedure
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Austria: ICON Customer Satisfaction Survey 2018
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Shortlisted with another nomination as “Austria Transfer Pricing Firm of the Year“

Austria: International Tax Review (ITR) awarded ICON as “Austria Tax Firm of the Year 2018”
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The deduction of incidental acquisition costs for private investors is not possible in case the special rate of 27.5 percent is applicable

Austria: Prohibition on deduction of incidental acquisition costs for private investors
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