(a) Applies to distributed and undistributed profits.
(b) In general, applicable to dividends paid to residents and nonresidents. Certain dividends paid to Austrian companies are exempt from tax
(c) Applicable to nonresidents.
(d) The offset of loss carryforwards against taxable income is limited to 75% of taxable income
This year saw a major tax reform in Austria as well as an economic recovery plan. Participation exemption rules were extended for portfolio dividends and personal income tax was cut. The government came under pressure to soften its banking secrecy laws, ...
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This year saw a major tax reform in Austria as well as an economic recovery plan. Participation exemption rules were extended for portfolio dividends and personal income tax was cut. The government came under pressure to soften its banking secrecy laws, which it has agreed to do. In the past, Austria would only relax these rules when there was a criminal investigation on matters such as tax fraud. Austria has agreed to renegotiate agreements with countries including Germany to help fight tax fraud and evasion. One commentator said, "The amendment to banking secrecy should be beneficial as it makes us an attractive investment market".
The tax authorities have also issued new tax reclaims regulations for foreign investment vehicles such as investment companies, collective investment funds and trusts. The new regulations are effective retroactively and apply to tax reclaims filed on or after January 1 2008, which have not yet been paid by the tax authorities.
Under the new tax reclaim regulations, foreign investment vehicles are considered as tax transparent entities. The underlying unit holders are considered as the beneficial owners of the Austrian-sourced income received by the investment vehicles.
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