Austria

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 Country-by-Country Report (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.