Austria

On 26 June 2025, the government bill of the Austrian Budget Accompanying Act 2025 ('Budgetbegleitgesetz 2025') was adopted by the National Council. It includes multiple amendments, primarily concerning the Austrian Real Estate Transfer Tax Regime, e.g.:

• Extensive tightening of taxation related to the share transfers in (Austrian) property-owning corporations and partnerships (share deals) and the taxation of real estate companies. 

• Comprehensive extensions to the Austrian Real Estate Transfer Tax Law (RETT-Law) as well as changes to the real estate income tax related to the taxation of profits from rezoning.
• Additional changes are planned in the areas of foundation entry tax, employee bonuses, and basic flat-rate scheme.

The Act was published in the Federal Law Gazette on 30 June 2025. 

On 18 March 2025, the Austrian Budget Stabilisation Measures Act 2025 (´Budgetsanierungsmaßnahmengesetz 2025') was published in the Federal Law Gazette. This Act includes measures to increase the tax revenue at short notice, such as the elimination of the zero VAT for photovoltaic systems, the extension of the energy crisis contributions, adjustments to the stability fee for banks, the engine-related insurance tax and the Austrian Law on Motor Vehicle Tax. 

On 17 July 2024, the Austrian Federal Act on the Publication of Country-by-Country Reports (CbCR) on Income Tax Information (‘CBCR-Veröffentlichungsgesetz’) was published in the Federal Law Gazette. See Transfer pricing in the Group taxation section for more information. 

On 19 July 2024, the Austrian Tax Amendment Act 2024 (‘Abgabenänderungsgesetz 2024’) was published in the Federal Law Gazette, which includes multiple amendments, e.g.:

• Changes in the tax group regime, e.g. stricter loss utilisation rules for a new group parent, electronic filing of the application for group taxation, introduction of an option with regard to offsetting a foreign group member´s losses.
• Extension of low-taxation tests for controlled foreign company (CFC) and local anti-hybrid purposes in accordance with Pillar II.
• Extension of the CbCR safe harbour rule and changes to the simplified calculation for hybrid structures.
• Limitations regarding the extensions of deadlines for the submission of tax returns.