HOW TO PROCEED
The Austrian Holding Company is an ordinary company which falls within the scope of general tax law and may benefit from the double taxation treaties concluded by Austria and the European tax directives.
There are no limitations on the activities of the company.
An Austrian Holding Company can be constituted as an “Aktiengesellschaft” (joint stock company- AG) or a “Gesellschaft mit beschraenkter Haftung” (private limited company- GmbH).
The minimum share capital for incorporation of an Austrian company is €70,000 for an « AG » and €35,000 for a « GmbH ». While the share capital of an « AG » must be fully paid up, for a company incorporated as a « GmbH » a minimum of €17,500 or the equivalent of 25% of the share capital must be paid up on incorporation.
Resident and non-resident companies are taxed at a flat rate of 25%. The Minimum tax payable is €1,750 for a Gmbh and €3,500 for an AG.
Capital duty of 1% is levied on the amount of capital contributed to a new corporation or when the capital of an existing corporation is increased:
The taxable income of an Austrian Company is based on the annual financial statements prepared in accordance with generally accepted accounting principles subject to adjustments and provisions.
Dividends received by an Austrian Company from:
An Austrian subsidiary are exempt from tax, regardless of the amount of participation held.
A non-resident subsidiary will not be subject to tax if the parent company owns at least 10% of the share capital for a minimum period of 1 year.
In order to benefit from the participation exemption, the following rules must be met:
Gains derived from the disposal of shares of a non-resident company in which the parent holds at least 10% of the share capital for a period of at least 1 year are exempt from tax. The previous antiabuse rules applied to dividends must also be applied to capital gains.
See income above.
Besides the common advantages of a holding company, the Austrian Holding Company may also enjoy from the following:
Dividends paid are exempt from withholding tax if the following conditions are met:
Interest and royalties paid by an Austrian company subject to unlimited corporation tax to an EU resident are exempt from withholding tax. The same exemption is applied for interest and royalties paid to a parent company which owns at least 25% of the payer for a minimum period of 1 year.
Double Tax Treaties
1Losses carry forward may only be offset against 75% of the profits of the year.
2If conditions are met.
A bespoke 'offshore' solution can be complex and requires careful planning and execution. We therefore encourage our clients to contact us directly, without obligation.
While all of our consultants in our offices provide a Free Initial Consultation, the consultant listed below has particular expertise in this area and will gladly assist with advice on how to approach your unique challenge.
Alternatively, to select one of our multilingual offices, click here for a list of our office contact details.
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