Mag. Matthias Mitterlehner

Liechtenstein's favorable tax rates attract international tax planning, but legal conflicts with Austria can lead to double taxation. A recent Austrian Fiscal Court case highlights the risks of complex tax avoidance schemes. 

Austria’s Pillar Two rules allow the ultimate parent entity to designate a "single taxable CE" for top-up tax, with the declaration to be filed via FinanzOnline by 31 December 2024.

The EU's Pillar Two Directive complements CFC legislation from ATAD. Austria adopted it in 2023, after implementing a CFC regime in 2018. The OECD later identified conflicts between the CFC legislation and Pillar Two.