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ARTICLE · 17 JANUARY 2019

Withholding Tax On Outbound Dividend Payments

The Austrian Ministry of Finance recently dealt with an interesting case of dividend payments made from an Austrian corporation to the Austrian permanent establishment of a French indirect shareholder.

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The Austrian Ministry of Finance recently dealt with an interesting case of dividend payments made from an Austrian corporation to the Austrian permanent establishment of a French indirect shareholder.

Under the Austrian provisions implementing the EU Parent/Subsidiary Directive (cf. sec. 94(2) of the Austrian Income Tax Act [Einkommensteuergesetz]), outbound dividends paid to non-resident shareholders are exempt from withholding tax in Austria, if (i) the shareholder holds a stake of at least 10% in the share capital of an Austrian corporation; and (ii) if the participation has been held for an uninterrupted period of at least one year. If the receiving company is resident in Austria, no minimum holding period is required for the exemption from withholding tax.

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