Important tax deadlines at year-end

We would like to inform you below about important tax deadlines, which generally end on 31 December 2025.

CbC reporting (using VPDG1 form)

In principle, ultimate parent companies (or “representing parent companies”) resident in Austria that are subject to reporting obligations under the Austrian Transfer Pricing Documentation Act (VPDG) with a financial year-end of 31 December 2024, must submit the country-by-country report (CbC report) no later than 31 December 2025 via FinanzOnline.

Furthermore, under the VPDG, every Austrian-resident business unit of a multinational enterprise group with consolidated annual revenues of at least EUR 750 million must inform the competent tax office by the last day of the reporting financial year about which group company will submit the CbC report (using the VPDG1 form).

Accordingly, we recommend reviewing whether there is an obligation to submit a VPDG1 form for your company via FinanzOnline.

Securities coverage for pension accruals

By 31 December 2025, the requirement for securities coverage of pension accruals must also be observed. If pension accruals are recognised, securities with a nominal value of at least 50% of the tax pension accrual of the previous year must be held at the end of each financial year. In the event of a securities undercoverage, the taxable income of the relevant financial year must be increased by 30% of the securities undercoverage, even if the undercoverage is only temporary (penalty surcharge).

To avoid securities undercoverage, we recommend regularly monitoring the status of the securities and the required securities coverage and, if necessary, acquiring securities before the balance sheet date.

Formation and changes of corporate tax groups – group application

To take advantage of group taxation according to section 9 of the Austrian Corporate Income Tax Act (KStG), in addition to maintaining a financial connection of more than 50% throughout the financial year, timely submission of a group application to the competent tax office is essential.

For the formation or expansion of a corporate tax group from the 2025 assessment onwards, the group application – for groups with a financial year-end of 31 December 2025 – must therefore be submitted to the competent tax office of the group parent, verifiably before the end of the calendar year and within one month after signing. Formal requirements regarding signing and submission to the tax office must also be observed in this context.