Austria’s parliament has amended its CFC rules to avoid double taxation issues under the Pillar Two global minimum tax framework.
Amendments to Section 10a of the Austrian Corporate Income Tax Act have been approved and now require that Qualified Domestic Minimum Top-up Tax (QDMTT) in a CFC’s residence state be included in the effective tax rate (ETR) calculation for CFC purposes.
Austria’s CFC rules do not apply if a foreign subsidiary of an Austrian parent company is subject to QDMTT that raises the foreign ETR to 15% to prevent double taxation.
Earlier, Austria’s Nationalrat approved the bill to ensure Pillar Two global minimum taxation for multinational enterprise (MNE) groups and large domestic groups in the EU on 14 December 2023.
