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The Austrian Holding Company

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The Austrian Holding Company

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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

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