The FAQs on the Minimum Taxation Act provide detailed guidance on technical topics like prior-period income, joint ventures, mergers, and filing obligations.
Austria’s Ministry of Finance published Part 2 of its FAQs on the Minimum Taxation Act on 27 June 2025, providing further guidance on the application of the legislation.
The updated FAQs address key technical aspects, including the treatment of income from prior periods, the treatment of joint ventures, and clarifications on mergers and demergers. They also provide guidance on submission deadlines for the minimum tax return, circumstances that give rise to an additional top-up tax amount, implications of group member sales or liquidations, and the application of the deemed consolidation test for identifying the ultimate parent entity.
Part 1 of the FAQs was released in June 2024 and focused on the scope of application, safe harbours, transitional provisions, and the entry into force of the Minimum Taxation Act. The Act aligns with global minimum tax standards under Pillar Two and introduces domestic implementation rules in Austria.
Earlier, the Austrian lower house of parliament (Nationalrat) approved Bill No. 2322 dB on the execution of the Minimum Taxation Directive (2022/2523) to ensure a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the European Union on 14 December 2023.
