Austrian Tax News. Salzburg Tax Dialog In this issue

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1 Austrian Tax News In this issue Direct Taxes Salzburg Tax Dialog 2013 by Guelay Karatas and Marko Kovacevic Highlights Salzburg Tax Dialog 2013 Austrian Restructuring Tax Act by Guelay Karatas and Lukas Bernwieser Conversion of a company after expatriation to Switzerland by Maria Hopfenwieser-Molzer and Philipp Sperker Exit tax upon moving from Austria to Switzerland by Maria Hopfenwieser-Molzer and Laura Herold Principle of correct overall profit vs. correct period taxation Profit adjustments in periods not covered by a statute of limitations by Alexander Wagner and Sebastian Heger Commercial activity tax of Ohio by Guelay Karatas and Lukas Plakolm Indirect Taxes VAT implications due to Croatia s accession to the EU by Gerald Dipplinger and Andreas Guttmann Legal Alternative Investment Funds Manager Act: The regulatory and tax impacts by Thomas Steinbauer, Florian Ortner and Johannes Edlbacher Austrian Tax Facts and Figures Salzburg Tax Dialog 2013 Austrian Ministry of Finance on the disposal of shares with retention of dividends and the antiabuse rules regarding international participation exemption subsequent local supplies to the customers. The Austrian Ministry of Finance discussed specific tax cases regarding corporate tax, with a particular focus on dividend income. Disposal of shares with retention of dividend distribution One case concerned an Austrian company selling its 30% share in an Austrian company for EUR 1m in According to the sales agreement, the seller is to still receive the 2012 dividend. The question discussed was whether the retained dividend would qualify as tax-exempt dividend income or as part of the sales price, thus being subject to capital gains taxation. According to the Ministry of Finance, the retained dividend is part of the sales price and therefore subject to corporate tax if the resolution on the distribution of the dividend has not been taken by the sales date. In this case, the retained dividend is obviously linked to the sale and can only be classified as part of the sales price from an economic point of view. On the other hand, if the resolution on the distribution of profits has been passed by the sales date, the retained dividend and the subsequent distribution of profits is to be attributed to the seller. Therefore, the retained dividend is to be treated as tax-exempt dividend income. Anti-abuse rules The second case was about the anti-abuse rules regarding participation exemption: An Austrian limited liability company (A) owns 100% of the shares of a corporation (B), tax resident

2 Direct Taxes in another EU Member State, which holds 100% of the shares of a subsidiary (C) which is resident in the same state. The main business purpose of B is the distribution of software. To carry out the distribution activities, significant licence fees have to be paid by B to its subsidiary, which is only subject to low taxation and only generates passive royalty income (i.e. no operating activity). In general, dividends distributed by company B to company A would be classified as tax-exempt dividend income under the Austrian international participation exemption rules. However, following the antiabuse rules, the participation exemption does not apply if the foreign subsidiary s income mainly consists of passive income which is not subject to tax comparable to Austrian corporate tax. According to the anti-abuse rules, passive income is assumed to exist if the foreign company mainly generates interest income, rental income from moveable assets or capital gains upon the sale of portfolio investments. According to the anti-abuse rules, passive income of lower-tier subsidiaries has to be taken into consideration when reviewing the nature of the dividend income. In this particular case, the main profit is generated from royalties. The income from the distribution activities is reduced significantly by the licence fees paid. As the royalty income of C is not subject to income tax comparable to Austrian corporate tax and the passive income prevails, the participation exemption is not applicable. g.karatas@at.pwc.com marko.kovacevic@at.pwc.com Highlights Salzburg Tax Dialog 2013 Austrian Restructuring Tax Act On 22 April 2013, the draft of the Salzburg Tax Dialog 2013 was published by the Austrian Ministry of Finance. In terms of the Austrian Restructuring Tax Act the discussion referred to the following issues: In-bound contribution of partnership interest In the case discussed, a German resident partnership (as 100% shareholder) and an Austrian corporation are the partners of an Austrian limited partnership. The German partnership is held by two German shareholders. The German partnership contributes its Austrian partnership interest to the Austrian corporation. The contribution is made without issuing any shares and qualifies as a contribution under the Austrian Restructuring Tax Act ( RTA ). Prior to the contribution, Austria is entitled to tax the profits of the Austrian partnership (at the level of its underlying German partners) at a progressive income tax rate of up to 50%. As a consequence of the contribution, the Austrian partnership collapses. The Austrian corporation takes over all of the Austrian partnership s assets/liabilities. At the level of the Austrian corporation, the profits become subject to Austrian corporate tax at a rate of 25%. The point discussed was whether the contribution resulted in a limitation of Austrian taxation rights since the applicable tax rate was reduced from up to 50% to 25% as a consequence of the contribution. Even though the German shareholders neither moved to Austria nor left Austria, the Austrian Ministry of Finance argues that the contribution falls within the scope of the 25% exit taxation. The view of the Austrian Ministry of Finance is based on the argumentation that the case at hand is comparable to exit constellations, meaning that whenever Austrian shareholders of an Austrian corporation shift their residence to Germany, Austria loses its taxation right in the Austrian shares. In the current case, the German shareholders may however apply for a deferral of taxation. Retrospective adjustments Under Austrian tax law, errors cannot be revised tax effectively once the statute of limitations has occurred. In specific cases, however, tax effective lump sum adjustments (additions/ deductions) are permitted. This applies on the condition that the respective error also affects years not yet statute-barred. If permitted, these adjustments have to be carried out in the first assessment period not yet time-barred. On this basis the possibility of retroactive adjustments in relation to contributions was discussed: Contribution I Two Austrian shareholders held partnership interests of 50% each in 2

3 Direct Taxes an Austrian partnership, which were contributed to an Austrian corporation in The contribution was intended to be carried out in a tax neutral manner under the RTA. As the contribution was effected without issuing any shares, one main prerequisite for a tax neutral contribution was not fulfilled. As a consequence, the contribution should therefore have triggered capital gains taxation at the level of the shareholders. In return, the receiving corporation should have capitalized the business assets received at fair market values and should have recognized goodwill (to be amortized over 15 years). In 2013, an amendment of the 2005 tax assessments of the corporation is not possible due to the statute of limitations. Austrian tax law principally provides for the possibility of considering a retroactive amendment in such cases by tax effective additions and deductions in years which are not yet statute-barred, provided the followup consequences of such adjustments also affect periods which are not yet subject to a statute of limitations. The Austrian Ministry of Finance, however, argues that the tax consequences of the contribution (realization of capital gains) and the tax consequences following the contribution (amortization of goodwill) affect different tax payers. On this basis no adjustment of the retroactive mistake is permitted. Contribution II Here, the circumstances correspond to those of Contribution I above, apart from the fact that the contribution is made in exchange for new shares. In addition, the partnership recognized expenses for construction in 2004 which should have been correctly capitalized instead and amortized over a 10-year period. The Austrian Ministry of Finance argues that Contribution II qualifies as a tax neutral contribution under the RTA, which is effected under universal succession (the corporation is the universal successor of the shareholders). On this basis the envisaged adjustment concerning the 10-year amortization does not affect different tax payers and a tax effective adjustment of the construction cost is permitted. g.karatas@at.pwc.com lukas.bernwieser@at.pwc.com Conversion of a company after expatriation to Switzerland Austrian Ministry of Finance on the tax implications for the shareholder in case of an expatriation to Switzerland followed by a conversion The Austrian Ministry of Finance recently issued a letter ruling (EAS 3334) which deals with the tax implications in a case where an Austrian individual holding shares in an operative Austrian corporation moves to Switzerland, followed by a tax neutral conversion of the Austrian corporation into a transparent partnership. Under the Double Tax Treaty Austria Switzerland, the expatriation of an Austrian individual to Switzerland does not trigger exit tax on any increase in value of the Austrian shares. The taxation of this increase will, however, be deferred until the shares are actually sold by the Swiss resident. Any increase in value of the shares attributable to the time after the move to Switzerland is not taxable in Austria under the Treaty. In the case of a subsequent tax neutral conversion of the Austrian corporation into a (transparent) partnership under the Austrian Restructuring Tax Act, the shares in the corporation are replaced by a partnership interest. Under general Austrian tax rules, the interest in an operating partnership qualifies as a permanent establishment of the foreign individual in Austria. Profits derived from the partnership as well as capital gains resulting from a future sale of the partnership interest are subject to up to 50% Austrian income tax. Upon conversion into the partnership, the assets of the Austrian company are tax neutrally stepped up to their fair market values. As a result of this tax neutral step-up, any increase in value until the conversion date would not be subject to Austrian tax in a future sale scenario. To avoid such non-taxation, this increase will be taxed at a rate of 25% once the assets are actually sold by the partnership or the partner. The letter ruling now states that this recapture rule does not, however, have an impact on the deferral of taxation of the increase in value of the shares in the former corporation resulting from the move of the individual to Switzerland. Both the move of the shareholder to Switzerland and the subsequent conversion of the Austrian corporation into a partnership do therefore not trigger immediate Austrian taxation. 3

4 Direct Taxes The letter ruling further states that the fair market value of the shares in the Austrian corporation as of the day of the expatriation of the individual could be seen as the fair market value of the assets of the Austrian corporation if no separate valuation of the assets was available at the level of the corporation at this date. at.pwc.com philipp.sperker@at.pwc.com Exit tax upon moving from Austria to Switzerland As a general domestic rule, exit taxation is typically applied when assets are transferred by a taxpayer from Austria to a foreign country. If the assets are transferred from Austria to another EU Member State or a country of the European Economic Area (EEA) which has entered into a comprehensive assistance agreement with Austria, a deferral of the actual exit tax payment can be applied until the assets are actually sold or transferred outside the European Union or the EEA. This exit taxation rule typically also applies to capital gains resulting from the transfer of shares in a corporation. According to Article 13 of the Double Tax Treaty Austria-Switzerland, capital gains resulting from the sale of the shares in a corporation are taxed in the country of residence of the owner of the shares. However, when the owner of such shares moves from one country to the other, any increase in value of such shares generated before the exit remains taxable in the exit state. This exit tax is triggered once the shares are actually sold. The Austrian Ministry of Finance has now published an opinion on this rule in case the shareholder of a Swiss corporation moves from Austria to Switzerland. In such cases, the increase in value of the Swiss shares generated up to the move of the shareholder from Austria to Switzerland is subject to Austrian income tax. According to the Austrian Ministry of Finance, Austrian exit tax has to be assessed in the year of exit, but the taxpayer can apply for the deferral of the tax payment until the actual sale of the shares. In the view of the Austrian Ministry of Finance, this approach is in line with Article 13 of the Double Tax Treaty with Switzerland as the mere assessment of the exit tax upon exit does not offend the rule that such exit tax is not incurred until the shares are actually sold by the (now) Swiss tax resident. maria.hopfenwieser-molzer@ at.pwc.com laura.herold@at.pwc.com Principle of correct overall profit vs. correct period taxation Profit adjustments in periods not covered by a statute of limitations On 14 December 2012, the Austrian Tax Amendment Act ( Abgabenänderungsgesetz ) 2012 was enacted, dealing amongst other things with balance sheet adjustments for tax purposes with respect to correct overall profit (Section 4 para 2 Austrian Income Tax Act/ ITA ). This amendment became effective on 1 January 2013 with respect to fiscal years as of 2003 not yet covered by a statute of limitations. Additionally, the Austrian Ministry of Finance recently adjusted the Austrian Income Tax Guidelines with respect to this amendment. Profit adjustments due to correct overall profit Basically, incorrect balance sheet approaches have to be adjusted in the year of origin. In former years, this principle might have led to an incorrect overall profit from a tax point of view if the adjustment of the profit was not possible for tax purposes due to the statute of limitations for this particular year. Consequently, a double taxation or a double non-taxation of expenses or earnings might have resulted. According to the amendment enacted by the Tax Amendment Act 2012, incorrect approaches still are to be adjusted in the year of origin (presumably covered by a statute of limitations). However, if the year of origin is covered by a statute of limitations and, additionally, tax periods not covered by a statute of limitations are affected, adjustments for tax purposes are to be considered in the first year not covered by the statute of limitations and possibly consecutive years. In contrast, if only periods covered by a statute of limitations are affected, no adjust- 4

5 Direct Taxes ments are possible according to this legal amendment. The same would apply if only periods not covered by a statute of limitations were affected. The adjustment is managed either by an increase or decrease of the taxable profit, resulting in a correct overall profit for tax purposes. Write-up on participations after current value depreciations in former years The Austrian Income Tax Act sets out an obligation for a write-up of participations after current value depreciations in former years, provided that the particular reason for the former deprecation does no longer exist. Since fiscal year 2009, the reasons for write-up or depreciation do no longer have to be specified. Thus, a writeup has to be considered in case of an appreciation in value of a specific participation irrespective of the underlying reason. The Austrian Tax Amendment Act now provides for an adjustment of the taxable profit via a premium (increase of taxable profit) in the first year not covered by a statute of limitations if write-ups with respect to appreciations in value relating to years before 2009 have not been considered due to the missing identification of reasons. Depreciation Change in the duration of useful economic life In general, the acquisition costs of assets are to be spread over their useful economic life. However, if the useful economic life has been calculated incorrectly, an adjustment is required (this applies only in case of considerable deviations at least 20%). As a general rule, the incorrect approach is to be adjusted in the year of origin. However, if the year of origin is already covered by a statute of limitations and, additionally, consecutive years are affected, an adjustment for tax purposes is to be considered through an increase/decrease of taxable profit beginning with the first year not covered by the statute of limitations. alexander.wagner@at.pwc.com sebastian.heger@at.pwc.com Commercial activity tax of Ohio In a recently issued letter ruling, the Austrian Ministry of Finance dealt with the creditability of Ohio s commercial activity tax. US state taxes are not covered by the Tax Treaty Austria USA. In the letter ruling, the possibility of a unilateral relief was reviewed. Under national law, foreign local taxes may be credited against Austrian income tax if the foreign local tax is comparable to Austrian income tax. Such comparability is assumed to exist if the foreign local tax is levied on the income of an individual or corporation. The commercial activity tax replaced the former local income tax of Ohio. According to the general information published by the Ohio Department of Taxation, the commercial activity tax is an annual tax imposed on the privilege of doing business in Ohio, measured by gross receipts from business activities in Ohio. The tax basis of Ohio s commercial activity tax is not the income, but the gross receipts which are comparable to gross sales. As a consequence, it does not fulfill the criteria of a personal income tax which can be credited against the Austrian income tax. According to the Austrian Ministry of Finance, the commercial activity tax therefore qualifies as impersonal tax which is deductible for Austrian income tax purposes. g.karatas@at.pwc.com lukas.plakolm@at.pwc.com VAT implications due to Croatia s accession to the EU Indirect Taxes Since 1 July 2013, Croatia has been the newest member of the European Union. Upon accession Croatia adopted the rules of the EU VAT Directive, in particular the VAT rules for the supply of goods and services. Supply of goods Goods dispatched from other Member States to taxable persons established in Croatia are no longer treated as export supply, but as intra-eu supply of goods in the country of dispatch. Therefore, the general rules, in particular the following invoice requirements, are to be met: The invoice is to show the VAT identification number (VAT-ID) of both the recipient and the supplier 5

6 Indirect Taxes as well as a reference that the supply of goods is zero-rated as intra-eu supply. As a consequence, Croatian businesses are to apply for a VAT-ID. The VAT-ID comprises the prefix HR followed by a Personal Identification Number (OIB) which contains eleven digits. It may take some time until all companies have received a Croatian VAT-ID. According to an information published by the Austrian Ministry of Finance for intra-eu supplies with respect to customers in Croatia who do not yet have a VAT-ID, a delivery to Croatia may nevertheless be treated as intra-eu supply if the purchaser of the goods confirms in writing that he has already applied for a VAT-ID and that he meets the conditions for obtaining it and the missing VAT-ID is added to invoices before the annual VAT return is to be filed. This temporary regulation is to apply until 1 January Supply of services With respect to services, the EU place-of-supply-rules apply. According to the B2B rule, services will be taxed where the business recipient of the service is established. The invoice is to include both the VAT-ID of the provider and the recipient of the service and to point out that this service is subject to a reverse charge. No VAT must be shown on the invoice. Distance sale of goods If goods are sold and dispatched to Croatian private individuals, the rules for distance selling apply: Distance sales to customers without VAT-ID are in principle taxed where the supplier of the goods is established. However, if the threshold of HRK (approximately EUR 35,640) is exceeded (or the application of the threshold is waived by the supplier), the place of supply moves to Croatia and Croatian VAT becomes due. gerald.dipplinger@at.pwc.com andreas.guttmann@at.pwc.com Legal Alternative Investment Funds Manager Act: The regulatory and tax impacts The Austrian Alternative Investment Funds Manager Act ( AIFMG ) was published in Federal Law Gazette I 135/2013 on 29 July 2013 and transposes the EU Alternative Investment Fund Manager Directive ( AIFMD ) into Austrian law. The Austrian AIFMG as well as the AIFMD seek to regulate the wide field of Alternative Investment Funds ( AIFs ) by establishing a harmonised and stringent regulatory and supervisory framework for Alternative Investment Fund Managers ( AIFM ). However, in Austria the AIFMG is not only a relevant regulatory law; it also entails tax consequences for any undertaking qualifying as an AIF since tax relevant sections in the Austrian Investment Fund Act ( InvFG ) and the Austrian Real Estate Investment Fund Act ( ImmoInvFG ) directly make reference to the AIFMG. Regulatory law AIF and AIFM under the Austrian AIFMG According to the Austrian AIFMG, the term AIF means open or closed collective investment undertakings regardless of their actual legal structure or legal form (trusts, partnerships, corporations, etc), including investment compartments thereof (umbrella funds and master-feeder funds), which raise capital from a number of investors with a view to investing it in accordance with a defined investment policy for the benefit of those investors. They are not authorized as UCITS vehicles. As a result, private equity, hedge, infrastructure, commodities and real estate funds generally fall within the scope of the AIFMG. However, the wide AIF definition means that investment arrangements which do not go along with the classic understanding of investment funds may also be covered by the AIFMG, e.g. single purpose vehicles set up by a group of investors to acquire real estate. Under the Austrian AIFMG, certain undertakings are explicitly exempted from the application of the AIFMG, including especially holding companies meeting certain criteria. Furthermore, the AIFMG is not to apply to undertakings having a general commercial or industrial purpose (operative business). However, what is to be regarded as a operative business is a legal grey area in dire need of clarification. The Austrian AIFMG defines the term AIFM as a legal person whose regular business involves managing one or more AIFs, whereby managing means performing at least the portfolio and 6

7 Legal risk management of an AIF. If the aggregate AIF assets under management by an AIFM do not exceed certain thresholds (EUR 100m or EUR 500m), the AIFM only needs to register with the Austrian Financial Market Authority ( FMA ) and is only subject to selected provisions of the AIFMG. All other AIFM generally need to apply for authorisation by the FMA and must comply with all regulations of the AIFMG. Only licensed AIFM may sell AIF units to private investors and distribute AIFs in the EU under the passport system. According to the Austrian FMA and the European Securities and Markets Authority ( ESMA ), the AIF definition has been intentionally drafted in broad terms in order to capture the vast variety of fund structures in the EU. The FMA and ESMA agree that whether a structure qualifies as an AIF can only be determined on a caseby-case basis. In this respect, Austrian AIFM may resort to the FMA for a notice of assessment determining whether they qualify as AIFM which would at least indirectly clarify whether an AIF exists. Nevertheless, leeway for interpretation and legal uncertainty remains. The latter is cause for grievance, as extensive tax consequences will arise subject to whether an undertaking qualifies as an AIF under the AIFMG. What are the implications of the AIFMG on Austrian tax rules? The transposition of the AIFMD into Austrian law also resulted in amendments being made to the sections in the InvFG and the ImmoInvFG regulating the qualification of Austrian and foreign investment undertakings as investment funds for tax purposes. Under the old rules, investment funds for tax purposes were deemed to be: Portfolios of assets established in accordance with the provisions of the InvFG or of the ImmoInvFG, jointly owned by the unit holders and managed by an Austrian investment management company; Foreign investment undertakings investing directly or indirectly based on risk spreading (six or more investments), regardless of legal form. However, even if the criterion of risk spreading were to be fulfilled, a foreign investment undertaking would not qualify as a foreign investment fund if the influence on the entrepreneurial activities of the underlying company went beyond a purely capital safeguard character. A capital participation of at least 25% in the underlying companies was a strong argument against a purely capital safeguard character, and therefore also against the qualification as a foreign investment fund. Under the new rules, the following are to be qualified as an investment fund for tax purposes: Portfolios of assets established in accordance with the provisions of the InvFG or of the ImmoInvFG, jointly owned by the unit holders and managed by an Austrian investment management company; Foreign investment undertakings qualified as an Undertaking for Collective Investment in Transferable Securities ( UCITS ) within the meaning of Directive 85/611/EEC; Austrian and foreign AIFs within the meaning of the AIFMG except for Austrian AIFs in real estate having the legal form of an Austrian corporation and for foreign AIFs in real estate, which are comparable to an Austrian corporation; Other foreign investment undertakings investing directly or indirectly based on risk spreading and which are not subject to a tax comparable to Austrian corporate tax. The new rules, which provide for an extension of the investment fund taxation rules especially also to private equity funds, are to apply to financial years starting after 21 July 2013, irrespective as to when the foreign vehicle was set up. Grandfathering rules for vehicles set up before 22 July 2013 were not introduced. Currently, there are a number of open questions concerning the new rules. These questions mainly deal with the regulatory qualification as an AIF and the interpretation of the term risk spreading. How are investment funds taxed in Austria? An investment fund is considered transparent, implicating a direct allocation of the fund s income to its investors. Besides the distributed income, the accumulated income is also taxable once a year as deemed distributed income ( DDI ). The DDI has to be calculated by an Austrian tax representative on an annual basis. Failure of a tax representative to calculate the DDI will result in the application of unfavourable lump-sum taxation (i.e. rendering at least 10% of market value as at 31 December taxable). The taxable income generally consists of dividend income, interest income minus expenses and realised capital gains. In the case of investments in real estate it should be considered that any unrealised profits from appreciation of the real estate will also be annually taxable. thomas.steinbauer@at.pwc.com florian.ortner@at.pwc.com johannes.edlbacher@at.pwc.com

8 Austrian Tax Facts and Figures Taxation of corporations Corporate income tax rate (Basis adjusted statutory accounts) 25% Non-deductible expenses (examples) Dividend withholding tax 25% Long-term accruals 20% Witholding tax on licences/royalties 20% Business meals 50% Interest witholding tax 0% Excessive car expenses for luxury cars Significant allowances Research & Development (R&D) (premium in cash) 10% Learning & Education (L&E) (Alternatively premiums in cash: 6%) up to 20% Double taxation agreements with 86 countries mainly exemption method International participation exemption for holding companies Conditions: Investments >10%, 1 year holding Dividends and Capital gains 0% Dividend EC portfolio (shares) < 10% 0% Thin capitalization rules None CFC rules None Tax loss carry forwards Losses may be carried forward for an indefinite period of time Usage of tax losses: 75% of taxable income Group taxation valid from January 2005 Consolidation of tax losses with taxable profits Conditions: Qualifying participations > 50% Group agreement and agreement on allocation of cost Losses of foreign participations may be offset against profits of group leader Annual taxable Income Tax Effective Tax Marginal Tax Rate to 11, % 0% over 11,000 to 25,000 over 25,000 to 60,000 Value added tax in line with the 6 th EU directive (EK - 11,000) x 5,110 14,000 (EK - 25,000) x 15,125 35,000 Standard rate 20% Reduced rate (Food, rent, public transportation etc.) 10% VAT refund for foreign enterprises available up to June 30 of the following year and for EU enterprises up to September 30 of the following year. Other taxes Real estate transfer tax 3.5% Capital tax 1.0% Stamp duties - Assignment agreements 0.8% - Rent agreements - Suretyship agreements % 36.50% + 5, % 43.21% over 60,000 (EK - 60,000) x 50% + 20,235 > 33.73% 50% Social security on monthly earnings up to 4,440 Employer s share up to 21.83% Payroll related taxes approx. 8.0% Employee s share up to 18.07% Income cap for social security contributions, social security totalisation agreements with various states 1.0% 1.0% Contacts PwC Österreich GmbH Wirtschaftsprüfungsgesellschaft Erdbergstraße 200, 1030 Vienna Austria Tel Tax Partners and Directors: Monika Berndl ext Ernst Biebl ext Doris Bramo-Hackel ext Alexandra Dolezel ext Marianna Dozsa ext Peter Draxler ext Herbert Greinecker ext Peter Hadl ext Bernd Hofmann ext Martin Jann ext Aline Kapp ext Matthias Kornberger ext Rudolf Krickl ext Kurt Lassacher ext Erik Malle ext Peter Perktold ext Friedrich Rödler ext Maria Schachner ext Thomas Steinbauer ext Thomas Strobach ext Christine Weinzierl ext Rupert Wiesinger ext Christof Wörndl ext Georg Zehetmayer ext ) ext. 2) ext. 3) ext. We encourage feedback on the newsletter and the content. Equally, we welcome any of your thoughts on topics that you would like to see addressed in future issues. Visit our website for archived Austrian Tax News: Copyright and Publisher: PwC Österreich GmbH Wirtschaftsprüfungsgesellschaft, Erdbergstraße 200, 1030 Vienna, Austria Editor: Christof Wörndl, christof.woerndl@at.pwc.com The above information is intended to provide general guidance only. It should not be used as a substitute for professional advice or as the basis for decisions or actions without prior consultation with your advisors. While every care has been taken in the preparation of the publication, no liability is accepted for any statement, option, error or omission. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see for further details.