The extensive use of guidelines and edicts is a striking distinguishing feature of tax law in comparison to other disciplines of Austrian law. In Austria, international institutions and the Federal Ministry of Finance have been trying for years to specify regulations in the field of international tax law and transfer pricing in non-binding guidelines (OECD transfer pricing principles, BEPS, VPR) and other statements (EAS). Julia Berchtold and Erich Lochmann intend to show that these “soft law" statements are often classified as legally non-binding and are rejected by the Austrian Federal Fiscal Court at the latest.
