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Austria intangibles guide

June 01, 2011

By Marianna Dozsa and Bettina Dorfer PwC, Austria

The Austrian Ministry of Finance (MoF) generally follows the positions of the OECD as expressed in the TP Guidelines, the model commentary and the various OECD reports (for example, partnership report, report on the attribution of profits to a PE). The Austrian MoF recently published transfer pricing guidelines, which specifically cover issues related to intangibles in connection with a number of subjects. Intangibles in Austria have appeared recently with regard to a number of taxpayer inquiries and continue to be important with regard to the selection of comparables.

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