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20
Austria – an attractive place
for holding companies
T
he following features
make Austria a favourable
jurisdiction for international
holding companies:
• a competitive tax rate of 25%;
• international participation
exemption for dividends and
capital gains received from foreign
subsidiaries;
• no thin capitalisation legislation;
• no CFC legislation;
• no withholding tax on interest paid
to non-residents;
• no withholding tax on dividends
paid to EC-resident parent
companies;
• extensive network of tax treaties
(more than 80 treaties, in particular
with all major Austrian trading
partners and with Eastern European
countries and former member
states of the USSR), reducing or
eliminating the general withholding
tax rate of 25% on dividends;
• tax rulings for transfer pricing and
group taxation issues;
• a group taxation system that allows
Austrian holding companies to
deduct losses incurred by foreign
subsidiaries;
• full deductibility of interest
expenses for loans in connection
with the acquisition of subsidiaries
that are not already members of the
group; and
• no wealth tax.
Establishing and funding
of an Austrian company
An Austrian holding company is
regularly established in the legal form of
a limited liability company (
Gesellschaft
mit beschränkter Haftung
, GmbH). The
establishment requires a notary deed and
a minimum share capital of €35,000; the
Presented by Robert Schneider,
partner at SchneideR’S Rechtsanwalts-KG
AUSTRIA
– Overview