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The Austrian Holding Company
Austria, right in the Center of the European Union and the historical gateway between East and West, serves as a perfect jurisdiction for establishing a Holding Company.
With an Austrian Holding Company one can obtain foreign source dividend income and capital gains resulting from the sale of shares in foreign corporations tax-free.
This tax exemption is also valid for dividends and capital gains from non-treaty countries or off-shore subsidiaries of the Austrian Holding Company.
Portfolio dividends (less than 10 % shareholding) also tax exempt
Other key features of the Austrian Holding Company:
- The Austrian Holding is not a special purpose vehicle but has access to all tax treaties (over 90 treaties)
- EU Parent-Subsidiary-Directive is applicable
- NO debt-equity rules / thin-cap rules
- Interest paid either to foreign or domestic lenders is fully tax deductible
- NO withholding tax on interest paid to foreign lenders, regardless whether lender is resident in a treaty country or not
- NO CFC-rules existing in Austria
- Written tax rulings from the tax administration can be obtained for sophisticated holding structures
- Contribution of foreign shares to an Austrian Holding give way to a tax-free step up in basis of the shares contributed
Please contact me for a personal meeting !
Erich Baier, MBA, LL.M. (Int’l Tax Law) TEP
Certified Tax Advisor
Austria, 1010 Vienna, Schwarzenbergstraße 1-3/14a
Phone: (+43 1) 516 12 0
Fax: (+43 1)516 12 14
mail: baier@austrian-taxes.com