Group taxation offsets a subsidiary loss in the year it arises, then recaptures it when the subsidiary returns to profit. The same-year benefit is a tracked, deferred liability.
- Asymmetric loss recapture in Gruppenbesteuerung
- First-tier-only foreign inclusion
- Which foreign subsidiaries can join an Austrian tax group?
Austria applies a flat 23% corporate income tax rate, unchanged since 2024 after a phased reduction from 25%, alongside a 20% standard VAT rate and employer social security contributions of 20.98% of gross salary under the ASVG system. Dividends are subject to 27.5% withholding tax (23% where the recipient is a corporation), reducible under double tax treaties. A GmbH can be formed with a reduced minimum share capital of €10,000 (€5,000 paid in cash) since 2024, or the standard €35,000 (€17,500 paid in) variant; an AG requires €70,000.
What a company pays in Austria. Every figure below is published on the Austria country page.
| Austria | |
|---|---|
| Corporate tax rate | 23% flat (minimum CIT: €500/year standard GmbH, €500/year reduced-capital GmbH billed at €125/quarter) |
| VAT standard rate | 20% |
| VAT reduced rates | 13% and 10% (10% narrowing to 4.9% for select basic foods from 1 July 2026) |
| Accounting standard | Austrian Commercial Code (Unternehmensgesetzbuch, UGB) |
| Currency | EUR |
What makes it complex in Austria
- Asymmetric loss recapture in Gruppenbesteuerung — — foreign subsidiary losses offset immediately against Austrian taxable income are clawed back and taxed once the subsidiary turns profitable or leaves the group.
- First-tier-only foreign inclusion — — only directly held (>50%) foreign subsidiaries resident in the EU or in states with a comprehensive administrative assistance agreement with Austria qualify for the tax group.
Which foreign subsidiaries can join an Austrian tax group?
Only first-tier foreign subsidiaries qualify: those held at more than 50% directly by an Austrian group member, and resident either in an EU member state or in a country that has a comprehensive administrative assistance arrangement with Austria. Lower-tier (indirectly held) foreign entities cannot be included.
How does Gruppenbesteuerung loss recapture actually work?
Losses of a foreign group member may be deducted from the Austrian group's taxable income in proportion to the direct shareholding, but these are timing benefits, not permanent deductions. If the foreign entity subsequently generates enough profit to use those same losses under its own domestic tax regime, or if it drops out of the group, the previously deducted amount is recaptured and taxed in Austria.
Asymmetric loss recapture in Gruppenbesteuerung is one of the points HTLC Network handles for clients operating in Austria, within a single engagement that covers every other country they operate in — executed locally, governed centrally.
In Austria the scope is: Statutory accounts under the Austrian Commercial Code (UGB), Firmenbuch filings, and corporate tax returns via FinanzOnline, including group-taxation (Gruppenbesteuerung) election and loss-recapture tracking where relevant.
See Accounting & Tax Compliance in Austria for the full scope, or the Austria country page for the statutory framework across every service.
Figures as published on the HTLC Network country pages, reviewed September 2026 and collected from public sources. They are not a substitute for advice on a specific case and should be verified before being relied on.