Austrian Corporate Tax

Currently, there are 90 tax treaties in force in Austria. Generally, they follow the OECD model, although some of the older treaties significantly deviate from the OECD model. Important examples of treaties which do not follow the OECD model in essential points are those with Brazil, France and Japan.

Austria does not have statutory thin capitalisation rules or safe harbour debt/equity ratios. However, depending on the economic situation of a company, the tax authorities may reclassify parts or all of a company’s debt into equity on a case-by-case basis. From a practical point of view it is thus definitely advisable to adhere to industry standards.

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