Austria

Austria

Austria’s Finance Ministry has opened a public consultation on proposed amendments to its global minimum tax rules for large corporate groups. The draft incorporates OECD administrative guidance issued in December 2023, May 2024, and January 2025. The proposed amendments explain how transparent, hybrid, and reverse hybrid entities are treated for tax purposes, and in addition presents new rules for recognizing and reconciling deferred taxes. The proposal also implements EU requirements for the automatic exchange of tax information under DAC9. Feedback on the proposal is due by November 3, 2025.

To read more on the Consultation Call, click here.

On March 13, 2025 the Federal Ministry of Finance in Austria published online the transfer pricing guidelines, updated as of March 11. The Guidelines offer detailed information and interpretation with regard to the application of the arm’s length principle in intercompany transactions. The updated regulations align with the OECD Transfer Pricing Guidelines, and also include important revisions from the OECD/G20 Base Erosion and Profit Shifting (BEPS) project.

To learn more on the guidelines, click here.

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