08/11/21
In September 2021, the Austrian Ministry of Finance published a draft update of the Corporate Income Tax Guidelines which primarily amends the guidelines in accordance with the latest case law and legislative changes. The 2021 update especially focuses on the new Austrian interest limitation rule (implementation of Article 4 of the EU Anti-Tax Avoidance Directive, ATAD). It is expected that the final version will be published early next year. Comments on the draft CIT guidelines have been provided by Austrian tax advisors and practitioners and hence some changes may be made in the final version.
The following points outline key aspects of the Austrian Ministry of Finance’s view on the interest limitation rule (a short overview of the interest limitation rule).
Authors: Matthias Mayer & Martina Gruber
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Editor: Eva Ebner, eva.ebner@pwc.com
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