The fourth issue covers the following topics:
- First arbitration procedure under a double tax treaty decided by the EJC;
- Forfeiture of tax loss carry-forwards due to substantial changes in shareholder structure; and
- Tax consequences if a 'home office' is considered a permanent establishment.
The topics focus on recent tax developments in Austria that may be relevant also for other jurisdictions.
Enjoy the reading!
Best wishes on behalf of the Wolf Theiss Tax team for a happy and successful 2018!