Basis of corporate income tax (Körperschaftsteuer)
Corporations (i.e. limited liability corporation [GmbH], stock corporation [AG]) are subject to unlimited taxation in Austria of their entire (domestic and foreign) income if they have their legal seat or place of effective management in Austria. A non-Austrian corporate tax resident (with neither a legal seat nor a place of effective management in Austria) is subject to limited taxation on certain sources of income in Austria.
Rates of corporate income tax (Körperschaftsteuer)
Due to the qualification of corporations as independent tax subjects, a distinction must always be made between tax ramifications at the level of the company and those at the shareholder level. At the level of the company, profits are taxed at the standard corporate income tax (CIT) rate of 25%, regardless of whether profits are retained or distributed. According to the Eco Social Tax Reform Act, the CIT rate will be reduced from 25% to 24% in calendar year 2023 and further to 23% in calendar year 2024.
At the shareholder level, the profit distributions are usually subject to withholding tax (WHT) of 25% for corporations and 27.5% for other recipients.
There is also a minimum CIT, payable by companies in a tax-loss position. The minimum CIT can be carried forward without time limitation and can be credited against future CIT burdens of the company.
The minimum CIT amounts to 875 euros (EUR) for an AG for each full quarter of a year.
The minimum CIT for a GmbH is EUR 437.50 for each full quarter of a year. However, for GmbHs founded after 30 June 2013, the minimum CIT amounts to EUR 125 for each full quarter of the first five years and EUR 250 for the next five years.
Local income taxes
There is no additional state or local income tax levied at the company level.