As part of the Tax Amendment Act 2005 (TAA), the Reorganization Tax Act (RTA) was approved by the first and second chambers of parliament on the 7 and 21 December 2005 respectively. The relevant amendments of the TAA regarding the RTA are as follows: (a) Creation of taxation rights as a result of cross-border reorganizations. If cross-border reorganizations lead to taxation rights in Austria, the assets transferred are valued at the fair market value. However, if these assets were previously part of a cross-border reorganization or transfer leading to a loss of Austrian taxation rights and the tax liability in...