The appointment of an alternative Pillar Two taxpayer in Austria, for taxpayers operating on a calendar year basis, is required to be submitted to the relevant tax office by 31 December 2024. Evidence of this appointment must be uploaded to FinanzOnline.
However, the ultimate parent entity (UPE) of a multinational group has the option to designate a different constituent entity as the Pillar Two taxpayer within the country.
In accordance with the Pillar Two regulations in Austria, only a single constituent entity is designated as the Pillar Two taxpayer responsible for submitting a preliminary declaration and remitting any necessary top-up tax.
In cases where multiple Austrian constituent entities exist, the entity deemed the “top” constituent entity is automatically recognised as the Pillar Two taxpayer. If no such top entity is present in Austria, the constituent entity with the greatest economic significance located in Austria will be regarded as the Pillar Two taxpayer.
