Austria: Taxable dividends vs. capital repayments

Austria: Taxable dividends vs. capital repayments

The Austrian Ministry of Finance in June 2015 published a draft bill regarding provisions under the Austrian tax reform 2015/2016. One of the proposed changes concerns the tax treatment of dividends paid by Austrian companies.


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The proposal would affect the determination as to whether a company’s distribution of profits is a qualified dividend (subject to withholding tax) or a repayment of capital (not subject to withholding tax but requiring a reduction of the tax book value of the participation on shareholder level).

The proposal would provide a “sequence” or rule for taxpayers to apply in determining whether a dividend would be qualified from a tax perspective.

Read a June 2015 report prepared by the KPMG member firm in Austria.

This KPMG report also examines other proposals form the 2015/2016 tax reform, included under the following topics:

  • Proposed changes on the taxation of real property
  • Restrictions on the use of losses from loss-sharing models
  • Changes to the Austrian bank secrecy rules
  • New rules regarding the real estate transfer taxes
  • Changes to personal and payroll tax

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