Austria

On 10 June 2026, the government’s draft of the Austrian Budget Accompanying Act 2027-2028 (‘Budgetbegleitgesetz 2027-2028’ or BBG 2027-2028) was approved.

• Key changes include the introduction of a progressive corporate tax rate from 2028, where income above EUR 1 million will be taxed at 24% instead of 23%. This mainly applies to fully taxable corporations. Corporate tax prepayments will be increased by 4.5%. For tax groups, the progressive rate will be applied at the group level on the consolidated group income.
• Starting with fiscal years ending in 2027, a deemed dividend rule targets shareholder loan accounts involving natural person, including persons related to shareholders and indirect shareholders. If the outstanding balance is not repaid or converted into an arm’s length loan by the day following the approval of the annual financial statements (or at the latest within five months), it will be considered a deemed dividend subject to withholding tax. A de minimis threshold of EUR 50,000 is applicable.
• For income tax purposes, the declining balance depreciation rate for electricity companies will be temporarily reduced from 30% to 10% for the fiscal years 2027 through 2029. Additionally, teleworking and workplace allowances will be eliminated starting in 2027, except for deductions for ergonomic furniture. The investment-related profit exemption will be limited to real asset investments during the 2027–2029 period, while investments in securities will be eligible again thereafter. Furthermore, the deductible acquisition costs for real estate capital gains will be lowered, and adjustments to the Family Bonus Plus payment-splitting provisions will take effect in 2027.
• Moreover, measures will be introduced from 2027 to exclude entrepreneurs suspected of financial offenses from certain VAT procedures for up to two years.
• The stability levy will maintain the existing rate until 2029 and will revert to pre-2025 levels from 2030. The related special payment will continue until 2028, be reduced significantly in 2029, and will end in 2030.
• Additionally, the BBG 2027-2028 includes the introduction of a package tax (‘Paketsteuergesetz’ or PakStG) which will come into effect on 1 October 2026.

On 29 December 2025, an amendment to the Austrian Corporate Income Tax Act 1988 (´Körperschaftsteuergesetz') was published in the Federal Law Gazette, harmonising an tightening low-taxation rules by raising the effective foreign tax rate threshold to 15% (from 12.5% for CFC inclusion and switch-over rules, and from 10% for the non-deductibility of interest and royalties). The amendments are generally effective for financial years beginning after 31 December 2025. No specific transitional rule is provided for the switch-over rules, meaning the underlying profits must already be taxed with at least 15% regardless of whether they arose before or after 31 December 2025.

The Anti-Fraud Act 2025 (`Betrugsbekämpfungsgesetz 2025`) was published in the Federal Law Gazette on 23 December 2025. It introduces a new criminal offense regarding the false declaration of losses and stipulates that the declaration of such losses should be regarded as tax evasion. Further changes include the extension of the scope of the surcharge for tax evasion under fiscal criminal law, the limitation of cash payments for taxes up to EUR 10,000, the exemption of certain taxes from insolvency-related clawback-claims, the abolition of input VAT deduction for high-value residential assets etc.

The government bill of the Crypto Reporting Obligations Act (´Krypto-Meldepflichtgesetz´), implementing the EU Directive on Administrative Cooperation (known as DAC 8), which is based on the Crypto-Asset Reporting Framework (CARF), was published on 20 November 2025.

The Austrian Act on Securing Business Locations 2025 (´Standortabsicherungsgesetz 2025´ or SAG) was published in the Federal Law Gazette on 31 October 2025. It aims at supporting Austrian companies that are expected to face significantly higher electricity costs due to the EU Emissions Trading System in the calendar years 2025 and 2026. The European Commission recently approved the funding guidelines for the SAG 2025. Funding applications can be submitted between 13 April and 30 September 2026.