Important Austrian tax deadlines as of 31 December 2025

We would like to inform that the deadline of December 31, 2025 has to be considered for the following tax aspects:

1) Notification on the CbC-Report (via the form VPDG1)

In principle, all reportable ultimate parent companies resident in Austria (or “representative parent companies”) within the meaning of the Austrian Law on Transfer Pricing Documentation (VPDG) have to submit the CbC-Report for the financial year 2024 via the online portal of the Austrian tax office (FinanzOnline) by December 31, 2025 at the latest (if the financial year of the entity corresponds to the calendar year).

Further, according to the VPDG all constituent entities resident in Austria that are part of a multinational group whose consolidated total turnover amounted to at least MEUR 750 in the previous financial year, are obliged to inform the competent Austrian tax office by the last day of the reportable financial year, about which group company files the CbC-Report (using the VPDG1 form).

Accordingly, we would like to remind you that the VPDG1 form of the reportable business unit must be submitted separately for each reportable financial year via FinanzOnline, including for the financial year 2025. However, submission is only required if there are changes compared to the previous year's report.

2) Sufficient cover of securities for pension provisions

As of December 31, 2025, the requirement of securities coverage for pension provisions has to be taken into consideration. If pension provisions are recognized in the balance sheet, it is required that securities with a nominal value of at least 50 % of the previous year's tax value of such pension provision are available at the end of the financial year. In case of a shortfall in securities, the tax result for the financial year must be increased by 30 % of the securities shortfall, even if the shortfall is only temporary (penalty surcharge).

In order to avoid a securities shortfall, we recommend checking the status of the securities and the required securities coverage regularly and, if necessary, acquiring securities before December 31, 2025.

3) Establishment of a new tax group/changes to an existing tax group - group application form

In order to benefit from the advantages of the Austrian group taxation regime pursuant to Sec 9 Austrian Corporate Income Tax Act, it is essential that, amongst others, the existence of a shareholding of more than 50 % between the relevant entities throughout the entire financial year is required. Further, a group application form has to be submitted to the competent tax office in due time.

If it is intended that the group taxation already comes into effect for the financial year 2025, the group application form must be signed by December 31, 2025 at the latest. Further, the group application form has to be submitted to the competent tax office of the group parent within one month after signing. Formal requirements regarding signing and submission to the tax office have to be considered.

4) Avoidance of interest payments on additional tax payments

If the 2024 corporate income tax return was not filed or assessed before October 1, 2025, and, if applicable, 2024 corporate income tax was paid in the amount of any additional payment or a deposit was paid in the amount of the anticipated additional payment of 2024 corporate income tax, claim interest began to accrue from that date at the rate of 2 % above the base interest rate (currently 3,53%) with respect to any additional payment of 2024 corporate income tax.

Please state the corresponding payment reference (“K 1-12/2024”) when making advance payments of corporate income tax, in order to ensure correct allocation of the payment.

5) VAT interest from the 2024 assessment

Additional claims (underpaid VAT) due to a tax assessment as a result of the submission of the 2024 annual VAT return will also be subject to interest (3,53%) from October 1, 2025, until the notice of assessment is issued. We therefore recommend finalizing the annual VAT return 2024 as soon as possible in case of an additional VAT claim.

6) Tax Prepayments on Capital Gains

In the case of interest from deposits at credit institutions and from other monetary claims against credit institutions within the meaning of Section 27a (1)(1) Income Tax Legislation (EstG), an advance payment shall be made by the withholding agent on 15 December. The advance payment shall be calculated as follows:

• The balance of current interest-bearing cash deposits and other cash receivables as of the last preceding annual financial statement
• The respective arithmetic average of the interest rates of the current calendar year attributable to current interest-bearing deposits and other monetary claims, determined by December 1 of the current calendar year
• The interest expense incurred up to October 30 of the current year for noncurrent interest-bearing deposits and other monetary claims. This interest expense shall be increased by 15%

The advance payment is 90% of the annual tax calculated from these values. The remaining capital gains tax is payable on September 30 of the following year.

7) Temporary increase in Investment Allowance

An investment allowance can be claimed as an operating expense for the acquisition or production of certain depreciable fixed assets from January 1, 2023 onwards. This allowance, which amounts to 10% of the acquisition or production costs, is granted in addition to depreciation. For assets in the area of ecologization, the allowance increases to a total of 15%. For eligible fixed assets, a temporary increase in the Investment Allowance — from 10% to 20%, and from 15% to 22% for assets related to ecologization — will be applicable from November 1, 2025, to December 31, 2026. The investment allowance remains capped at a maximum of EUR 1,000,000 per financial year.

Should you require more information on any of these issues, we are happy to be at your disposal. Further, we are happy to assist you with the preparation or the submission of the notification concerning the CbC-Report.