Page 10 - CEE Tax Guide 2025

Austria

Forvis Mazars
Business Services GmbH
Kärntner Ring 5–7 1010 Vienna
Phone: +43 1 531 74-0
www.forvismazars.com/at

Corporate taxes and other direct taxes There is a yearly minimum CIT amounting to EUR
3,500 for public companies (AG) and EUR 500 for
Under domestic tax laws, corporations are limited liability companies (GmbH). Any unused
deemed to be tax resident in Austria if they have minimum amounts can be offset against future CIT
either their registered seat or their effective payment obligations.
place of management in Austria. In this case, the
global income of the corporation is generally Tax losses can be carried forward indefinitely (but
subject to Austrian corporate income tax. Other only 75% of the profit of a single year can be offset).
corporations are subject to Austrian corporate Thin capitalization rules (TCR) are in place
income tax only on the basis of income generated in accordance with the EU-ATAD (Anti-Tax
from Austrian sources. Partnerships are not subject Avoidance Directive). Further restrictions relate
to CIT. The corporate income tax rate is 23%. to the deduction of interest paid to intercompany
The tax base is generally determined based on the recipients. CFC rules were introduced in accordance
result of the income statement under commercial with the EU-ATAD.
law, which is then amended insofar as the tax
law contains deviating rules (e.g. tax exemptions, Some 100 double tax treaties are in place.
restrictions of deductions, or tax-specific Withholding tax can be reduced at source to treaty
valuation rules). rates or under the EU-Parent-Subsidiary Directive,
if formal requirements are met.
Transfer pricing in Austria Global minimum tax (Pillar II) is applicable now
(details see below).
Arm’s length principle Since 1988

Documentation liability Since 1988 / VAT and other indirect taxes
extended in 2016
VAT options in Austria Applicable / limits
APA Since 2011
Distance selling As of July 1, 2021,
Country-by-Country Business units of large the OSS system is applicable.
liability MNE’s must notify who
is the reporting entity. Call-off stock

Master file-local file For groups with sales VAT group registration
(OECD BEPS 13) exceeding EUR 50m.
applicable Cash accounting – yearly EUR 700,000/year *
amount in EUR (approx.)*
Penalty
Import VAT deferment
lack of documentation Up to EUR 50,000.
Local reverse charge Examples: Electricity, emission
tax shortage Potential fines according quotas, cell phones, construction
to Tax Criminal Law. services, etc.

Related parties > 50% Persons who are Option for taxation
linked directly
or indirectly by ownership letting of real estate
(capital) or control.
supply of used real estate
Safe harbors No not applicable VAT registration EUR 55,000/year**
threshold**
Level of attention paid 8/10
by Tax Authority * Not applicable for corporate enterprises.
** VAT exemption for domestic small businesses.
Central and Eastern European tax guide 2025 Forvis Mazars 10