Austria - Deductibility of Interest and Royalties Restricted: Is Austria a BEPS Role Model?
- H. Peyerl
- European Taxation, 2014 (Volume 54), No 12
- 5 November 2014
In response to the OECD BEPS Action Plan, Austria, by means of its 2014 Tax Reform Act, eliminated the possibility to deduct interest and royalty payments within a group of companies where the receiving company is taxed at a tax rate that is lower than 10%. This note examines the effects of this new provision and the questions arising therefrom with regard to tax treaties and EU law.