20.11.2025

Update from the Austrian Supreme Administrative Court: prohibition on deduction of manager remuneration in connection with the research premium generally not applicable

In its recently published decision (30/09/2025, Ro 2024/13/0017-6), the Austrian Supreme Administrative Court (VwGH) ruled that the prohibition on deduction of manager remuneration pursuant to section 20 para. 1 subsec. 7 Austrian Income Tax Act (EStG) is not applicable for calculating the assessment base for the research premium, thus amending the Austrian Federal Financial Court […]

FB twitter Linkedin

21.12.2022

Austrian Supreme Administrative Court (VwGH) on seamless transition in cases of mergers within company groups

In principle, section 9 para. 5 Austrian Corporate Income Tax Act (KStG) provides that a merger within the company group does not result in the merging company exiting the company group or in other changes to the company group. The Austrian Supreme Administrative Court addressed a special situation in its decision of 19 October 2022, […]

FB twitter Linkedin