Austria’s tax authorities published a decree in the Official Gazette on the temporary CbCR Safe Harbor (CbCR Safe Harbor Regulation) under the Minimum Taxation Act (“MinBestG”) on 5 December 2024. The MinBestG, which came into force on 31 December 2023, led to a significant administrative burden for taxpayers. In order to eliminate some of this burden, taxpayers may take advantage of the CbC reporting safe harbors, which are based on simplified calculations.
The decree outlines the prerequisites for the qualified financial statements and country-by-country reports required for the Transitional CbCR Safe Harbour Tests, as stipulated in Article 55 (3) of the MinBestG.
This decree provides greater clarity on how businesses can comply with the new regulations, particularly in regard to the financial data and reporting needed for the safe harbour tests.
The regulation applies retroactively to financial years starting after 31 December 2023.
