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Austria - Deductibility of Interest and Royalties Restricted: Is Austria a BEPS Role Model?

Country:
Austria
Author:
H. Peyerl
Issue:
European Taxation, 2014 (Volume 54), No 12
Published:
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.
 
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