Deductibility of Interest and Royalties Restricted: Is Austria a BEPS Role Model?

Journal
Author
Peyerl, H.
Country
Austria
Published Date
Issue
European Taxation 2014 (Volume 54), No. 12
FormatPDF
EUR
45
| USD
50 (VAT excl.)

In response to the OECD BEPS Action Plan, Austria, by means of its 2014 Tax Reform Act, eliminated the possibility to deduct interest and royalty payments within a group of companies where the receiving company is taxed at a tax rate that is lower than 10%. This note examines the effects of this new provision and the questions arising therefrom with regard to tax treaties and EU law.