Der Ministerialentwurf für ein DBA-Durchführungsgesetz

A ministerial draft bill on statutory law with regard to specified issues of tax treaty application was sent out for comments in a public hearings procedure. The main goals of the new law are :• to clarify the interaction of treaty law and domestic law (sec. 1);• to allow for a set-off of losses incurred in foreign permanent establishments notwithstanding the exemption system available under most Austrian tax treaties (sec. 2);• to ensure appropriate taxation of income allocated to Austria...