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.
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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