The new Foreign Tax Application Decree of 22.12.2023: Selected aspects of add-back taxation in the fund context

On December 22, 2023, the tax authorities published the final Foreign Tax Application Decree as an early Christmas present. Particularly relevant in the context of funds are the statements on add-back taxation and the adjustments compared to the draft application letter from July 2023. Raphael Baumgartner explains the changes brought about by the final letter in his article.