Private Foundations: New standpoint of the Austrian Supreme Administrative Court on the transfer of hidden reserves pursuant to section 13 para. 4 KStG (Austrian Corporate Income Tax Act)

As a general rule, section 13 para. 4 KStG permits Austrian private foundations to carry over hidden reserves from the sale of investments (in which the foundation or its legal predecessor held a share of at least 1% within the last five years) to substitute investments. These substitute investments must involve the acquisition of a […]