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

Journal
Peyerl, H.
Austria
European Taxation 2014 (Volume 54), No. 12
PriceUSD 45

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.