Austrian restrictions on the deduction of interest

This paper examines the Austrian interest deduction restrictions under tax law and the question of whether these provide sufficient protection against the shifting of profits and tax bases in the context of the OECD's BEPS project and the European Union's Anti-BEPS Directive. The BEPS project has resulted in 15 final reports on various topics relating to the erosion of the tax base and the shifting of profits. The final report on Action 4 includes, as a key measure, the so-called interest barrier, which is closely modelled on the interest deduction restrictions in Germany. This paper first examines the German interest shield, then explains the contents and recommendations of this final report and discusses the resulting Anti-BEPS Directive. Subsequently, the interest deduction restrictions in Austria are described and compared with the European Union's requirements to determine any need for adjustment in Austria.

Pagina's: 76, Paperback, Our Knowledge Publishing