Austria: Claw-back of foreign tax losses | KPMG Global
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Austria: Claw-back of foreign tax losses, tax group dissolution

Austria: Claw-back of foreign tax losses

The Austrian Administrative Supreme Court held that when a tax group was dissolved, the foreign tax losses that are clawed back are those relating to the last financial year of the tax group’s existence.


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The court’s opinion upholds the position of the Ministry of Finance concerning a provision in Austrian tax law that previously used foreign tax losses must be clawed back if the Austrian group member leaves the group or the group is dissolved.


Read a January 2018 report [PDF 318 KB] prepared by the KPMG member firm in Austria

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