How corporate tax works in Austria
Austria taxes resident companies on worldwide income at a flat 23%, cut from 25% through 2024. There is no local corporate surcharge.
Groups with over 50% capital and voting ties attribute profits and losses fully for three-plus years, with foreign losses recognised pro-rata and capped. Minimum tax of EUR 500 yearly for a GmbH prepays the bill and carries forward.
Groups above EUR 750 million turnover face the 15% Pillar Two minimum through domestic top-up, IIR and UTPR rules. Dividends from qualifying international participations are largely exempt.
Tax rates at a glance
- Corporate rate
- 23%Flat
- Minimum GmbH
- EUR 500
- Minimum AG
- EUR 3,500
- Group attribution
- 100%
- Pillar Two minimum
- 15%
Who benefits most
These profiles tend to benefit most when the rules match their real residence, payroll and business setup.
FoundersHolding companiesRegional operatorsInvestorsCross-border groups
Watch out for
- Austria is cheap for companies and costly for staff. A 23% corporate rate beside 55% top salary tax makes owner-manager pay mix the central decision.
- Group taxation needs a real application and three-year commitment. Informal profit pooling without election gets no attribution.
- Foreign loss use is capped at 75% of domestic profit. Cross-border groups cannot wipe out Austrian tax with imported losses.
- Treaty withholding relief runs through refund or relief-at-source with forms. Payers need the paperwork before applying 5% instead of 27.5%.
Frequently asked questions
Does Austria have corporate tax?
Yes, a flat 23% on company profits with no local surcharge and full group taxation for qualifying holdings.
What is the minimum corporate tax in Austria?
EUR 500 a year for a GmbH and EUR 3,500 for an AG, fully creditable against real profits without time limit.
Are foreign losses usable in Austria?
Within tax groups, losses of EU or assistance-state subsidiaries attribute pro-rata, capped at 75% of domestic profit.