Austria: Capital repayment and internal financing | KPMG | GLOBAL
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Austria: Decree on capital repayment and internal financing

Austria: Capital repayment and internal financing

The Austrian Ministry of Finance published a decree on capital repayment and internal financing that concerns the requirements for capital repayment and distribution of profits.


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For the first time, a distinction between available and unavailable sub-accounts of capital contributions and internal financing has been made. Compared to a draft version, the decree simplifies the requirements for small and medium-sized limited liability companies (GmbH). 

In filing the 2016 tax return, it may further be possible for taxpayers to adjust the calculation of the internal financing (once) if this calculation was done for the first time before the publication of the decree.


Read an October 2017 report [PDF 324 KB] prepared by the KPMG member firm in Austria


Additional topics discussed in this report include:

  • Point in time of recognition of final losses resulting from an international participation in case of a liquidation
  • Tax treatment of disproportional loss allocation
  • Repeal of untaxed reserves in the Austrian Commercial Code
  • Exemption from capital gains taxation, real property of individuals
  • Contribution-in-kind of a business if real property is retained
  • German provision regarding the documentation of profit allocations
  • Deduction of input value added tax (VAT) for costs related to the sale of a participation

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