Austrian Tax Court declares horizontal group to be permissible

In a decision of 31 March 2022 (RV/7104573/2020), the Austrian Federal Tax Court (BFG) has stated – contrary to the wording of Sec 9 Austrian Corporate Income Tax Act (KStG) – that a company group between Austrian affiliates is permissible even if the joint parent company is resident abroad and does not have a branch in Austria. […]

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