Overview

The disclosure of hidden distributions and hidden contributions is one of the standard methods under Austrian corporate tax law. However, the rapid evolution of tax law has made disguised distributions and disguised contributions appear less and less attractive from the perspective of taxpayers. More precisely, the advantageousness has been reversed. The concealment of corporate transactions in supposedly business transactions between the corporation and the shareholder has been supplanted by the contrarius actus to do so. This contrarius actus consists of hiding appropriate service relationships between the corporation and the shareholder in transactions under corporate law (hidden service relationships). This book deals with the treatment of such hidden service relationships. In this context, the distinction between transactions under company law and service relationships plays a particularly important role.

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