Federal Cabinet: Government draft of a law for the implementation of “DAC 7” and for the modernization of tax procedural law
- The federal cabinet has passed the government draft of the law for the “DAC 7” implementation and for the modernization of tax procedural law.
- From a procedural point of view, the focus is on changes to modernize the external audit, which are particularly important from a transfer pricing perspective.
- According to the explanatory memorandum to the law, the focus is on cooperation between the tax authorities and companies. External auditors and taxpayers would be held accountable in equal measure.
- What is new in the government draft is the regulation according to which, in cases where advice has been given, an examination order should generally be issued by the end of the calendar year following the calendar year in which the tax assessment issued on the basis of the tax return became effective. If the tax authorities are responsible for a delay in this regard, the new period for limiting the suspension of expiry begins to run earlier.
- The timing of the application of the amendments to the AO is also structured in a somewhat more differentiated manner in the government draft than in the draft bill.
- The legislative process is scheduled to be completed by the end of 2022.
Source WTS
