DOUBLE TAXATION | No unilateral relief for failed tax structures!
International tax structuring can lead to multiple taxation if it fails. In this regard, a recent decision by the Austrian Fiscal Court discussed the need for unilateral relief from double taxation provided under Austrian law in the case of failed tax structuring involving trusts and private foundations under the laws of Liechtenstein.
Conclusion
Before you utilise cross-border structures for your business activities, you should always seek professional tax law advice. As experts in international tax law, we regularly deal with such cases and can show you the possibilities and limitations of using foreign companies and regimes. Please do not hesitate to contact the authors or the other experts in our "International Tax" and "Private Clients" service lines!
