Tax tip applies to entrepreneurs in Austria tax structuring for entrepreneurs from Austria Austria as a high-tax country for entrepreneurs. Therefore, businesses established search for possibilities of legal control in Austria. One way is the shifting of income in a low-tax country. To achieve this, a permanent establishment must be in the low-tax country analog 5 DBA (double taxation), in Austria no tax facility. Abuse of a design (illegal intermediate society), countries in the European Union are usually. Tags are: effect of EU freedom of establishment and judgments of the European Court of Justice on the freedom of establishment, Postivwirkung of the EU parent subsidiary directive or EU merger directive, positive effect of permanent establishment definition in the double taxation agreements. Within the EU, Cyprus and Bulgaria have the lowest taxes without conditions (10% income tax), tax-based company the special zones of ZEC (Special Canary, zone) and Madeira with 5%, but with appropriate conditions (creation of jobs or investment).
Cyprus is suitable for businesses established in the EU in particular, because: only 10% income tax dividend payments to non-Cypriots are subject to any withholding tax on Cyprus positive effects of EU freedom of establishment, EU mother subsidiary directive or EU merger directive the following design describes the possibility of tax-free capture the Cypriot dividends at the Austrian shareholder subject to progression. Therefore, the permanent establishment profits in Cyprus are taxed at 10%, the profits are captured by the Austrian “shareholder” steuerfrei-subject to progression. Of course such a design only works, if Cyprus is not a pure “letter box company”, but appropriate substance escape exists. In addition, “The place of the business management” on Cyprus must be situated, if no factory, no place for the exploitation of Natural resources or a construction longer than 9-12 months duration: either the client-oder a Beauftragter-moved his residence to Cyprus and acts as a Director of Cypriot limited or our tax law firm represents a trust or hired Director on Cyprus. .