Austria Country Profile

Austria Country Profile

Key tax factors for efficient cross-border business and investment involving Austria.


Related content

business people standing in a modern courtyard

EU Member State


Double Tax Treaties


Albania Denmark Kuwait Poland Turkmenistan 
Algeria Egypt Kyrgyzstan Portugal UAE
Armenia Estonia  Latvia Qatar UK
Australia Faroe Islands Liechtenstein  Romania Ukraine
Azerbaijan Finland Lithuania Russia US
Bahrain France Luxembourg San Marino Uzbekistan
Barbados Georgia Macedonia Saudi Arabia Venezuela
Belarus Germany Malaysia Serbia  Vietnam
Belgium Greece  Malta Singapore  
Belize Hong Kong  Mexico Slovakia  
Bosnia & Herzegovina Hungary Montenegro  Slovenia  
Brazil India Moldova South Africa  
Bulgaria Indonesia Mongolia Spain   
Canada Iran Morocco  Sweden  
Chile  Ireland Nepal Switzerland
China Israel Netherlands  Taiwan  
Croatia Italy New Zealand Tajikistan  
Cuba Japan Norway  Thailand   
Cyprus Kazakhstan Pakistan Tunisia  
Czech Rep. Rep. of Korea  Philippines  Turkey  

Most important forms of doing business

Limited Liability Company (GmbH) and Stock Company (AG).

Legal entity capital requirements

The statutory minimum share capital, amounts to EUR 35,000 for a GmbH, and EUR 70,000 for a AG. At least 50% of the share capital has to be paid in cash before registration.

Residence and tax system

A company is resident if either its legal seat or its place of management is in Austria. Resident companies are taxed on their worldwide income. Non-resident companies are taxed only on their Austrian source income.

Compliance requirements for CIT purposes

Deadline for filing tax return is April 30 (in hardcopy) or June 30 (via internet) of the following tax year; exemptions apply if the return is prepared by a professional tax advisory firm.

Corporate income tax rate

The standard corporate income tax rate is 25 percent.

Withholding tax rates

On dividends paid to non-resident companies

25 percent (exemption for payments to certain EU affiliates).

On interest paid to non-resident companies

0 percent.

On patent royalties and certain copyright royalties paid to non-resident companies

20 percent (exemption for payments to certain EU affiliates).

On fees for technical services

20 percent if work is executed in Austria.

On other payments


Branch withholding taxes


Holding rules

Dividend received from resident/non-resident subsidiaries

Full exemption. For foreign participations: no minimum participation or  minimum holding period is required subject to minimum taxation of distributing company (and exchange of information agreement for non-EEA companies). For domestic participations: no minimum participation or holding required.

Capital gains obtained from resident/non-resident subsidiaries

Capital gains on the disposal of shares in non-resident companies may qualify for a participation exemption (under certain conditions). Option for taxable status available. Domestic capital gains are always taxable at 25 percent.

Tax losses

Losses may be carried forward indefinitely. No carry-back is allowed. Losses carried forward may be lost after a substantial change in ownership of the company’s share capital or, in certain circumstances, a reorganization. Minimum taxation: 75 percent of the annual income can be sheltered by tax loss carry-forward, whereas 25 percent is subject to an immediate tax liability.

Tax consolidation rules/Group relief rules

Group companies (and, under certain circumstances, non-resident companies) can consolidate their profits and losses.

Losses of non-resident members can be offset against a maximum of 75 percent of the profits of resident members (from 2015 onwards), profits of non-resident group members are not consolidated. Applies only to group members from EU member states and to companies from countries with which Austria has entered into full administrative assistance.

Registration duties


Transfer duties

On the transfer of shares


On the transfer of land and buildings

Real estate transfer tax is triggered when (i) real estate is directly transferred or (ii) at least 95 percent of the company shares are transferred to one shareholder or a group of companies subject to group taxation. Rate: 3.5 percent of the consideration if real estate is directly transferred; if there is a transfer of 95 percent to one shareholder or a group of companies, the tax base is formed by real estate value (usually below the fair market value). Special provisions apply to transfers of interest in partnerships.

Stamp duties

Yes, the rate depends on the type of contract.

Real estate taxes

Yes, real estate transfer tax of 3.5 percent plus 1.1 percent cadastre registry fee of the consideration and real estate tax between 0.5 permille and 1.5 permille on the assessed value.

Controlled Foreign Company rules

Yes, specific anti-abuse provision.

Transfer pricing rules

Transfer pricing guidelines were issued by the Federal Ministry of Finance in 2010 and refer to the OECD Guidelines, the authorized OECD approach and various court decisions. Although not legally binding, they serve as a guideline for tax audits.

Documentation requirement

The non-binding transfer pricing guidelines also include detailed documentation requirements. An implicit obligation relating to detailed documentation on transfer prices is also derived from general provisions of the Federal Fiscal Code.

Thin capitalization rules

No specific thin capitalization legislation. According to administrative practice and court rulings, a debt-to-equity ratio of between 3:1 and 4:1 is recommended.

General Anti-Avoidance rules (GAAR)

A general anti-avoidance rule is included in the Federal Fiscal Code implementing a 'substance over form' principle.

Specific Anti-Avoidance rules/Anti Treaty Shopping Provisions

Dividends from international holdings are taxable with a credit for underlying tax rather than exempt if covered by an ordinance of the Federal Minister of Finance to avoid tax fraud and abuse. This can be assumed if in general:

  • The core business of the foreign company is to derive income, directly or indirectly, from loans, the lease of tangible or intangible assets, or the sale of participations (income test); and
  • The foreign company does not meet an effective minimum taxation test (i.e., foreign taxation is less than 15 percent of the effective tax rate under Austrian law).

Advance Ruling system

Yes, but limited to certain issues (transfer pricing, reorganization tax matters and tax groups).

IP / R&D incentives

Premium for costs incurred for R&D.

Other incentives



The standard rate is 20 percent and the reduced rate is 10 percent.

Other relevant points of attention


Contact us

Ulf Zehetner

KPMG in Austria

T: +43 1 31332 414



Christoph Plott

KPMG in Austria

T: +43 1 31332 697



Michael Petritz

KPMG in Austria

T: +43 1 31332 3304


EU Tax Centre

KPMG’s EU Tax Centre, working together with our network of EU tax law specialists throughout the European Union.

Read more

Connect with us


Request for proposal



KPMG's new digital platform

KPMG International has created a state of the art digital platform that enhances your experience, optimized to discover new and related content.