On 12 September 2023, the Austrian Ministry of Finance published an updated guidance on the explanation and application of the rules of DAC6 in Austria. This update is a practical guide to understanding EU-MPfG compliance, based on questions and comments received by the Federal Ministry of Finance.
The updated guidance provides additional clarifications on a number of key areas, including the meaning of tax advantage, transfer pricing structures, and the main benefit test. It also provides additional examples of persons who qualify as intermediaries. The revised guidance addresses familiar areas as the initial guidance, encompassing details regarding covered taxes, terminology definitions, reportable arrangements, hallmarks, the main benefit test and reporting deadlines.