The importance given by the Austrian government to the foreign investments is the reason why so many double tax treaties were signed.
The double tax treaties regarding income and capital were signed over the years with: Albania, Algeria, Argentina (not available anymore), Armenia, Azerbaijan, Australia, Barbados, Bahrain, Belarus, Belgium, Belize, Bosnia and Herzegovina, Brazil, Bulgaria, Canada, Chile, China, Croatia, Cuba, Cyprus, Czech Republic, Denmark, Egypt, Estonia, Finland, France, Germany, Georgia, Greece, Hong Kong, Hungary, India, Indonesia, Iran, Ireland, Italy, Japan, Kazakhstan, Kyrgyzstan, Korea, Kuwait, Latvia, Libya, Liechtenstein, Lithuania, Luxembourg, Malaysia, Malta, Macedonia, Mexico, Morocco, Moldova, Mongolia, New Zealand, Nepal, Netherlands, Norway, Qatar, Pakistan, Philippines, Portugal, Romania, Russia, San Martino, Saudi Arabia, Serbia, Singapore, Slovakia, Slovenia, Spain, South Africa, Sweden, Switzerland, Syria, Tajikistan, Thailand, Tunisia, turkey, Turkmenistan, United Kingdom, Russian Federation, Ukraine, United Arab Emirates, United States of America, Uzbekistan, Venezuela, Vietnam.
Double tax treaties on inheritance and gift taxes were signed with Czech Republic, France, Germany, Hungary, Liechtenstein, Netherlands, Sweden, Switzerland, United States of America.
Table of Contents
The main provisions of the double tax treaties
As a general rule, a double tax treaty is regulating the payment of taxes between two signatory states in order to avoid the double taxation of incomes and profits in both countries.
The double tax treaties provisions may be applied in various forms in order for the foreign investors to benefit from their advantages. A form of applying it is at the source by the paying agent. This method is called relief at source. This is possible by filling specific documents by the recipients of the payments and the payer agents.
Certain bodies cannot benefit from the relief at source:
– the trusts,
– the pure holding companies,
– the foundations,
– the investments funds,
– letterbox companies,
– other specified by the double tax regulations.
The refund of Austrian tax is possible when the paying agent has deducted tax at source, but the double tax treaty stipulates that full or partial exemption is applicable. In this case, an application must be send to the authorized tax office along with relevant documents.
A holding company may benefit from the double tax provisions if the beneficial owners are disclosed.
Along with the double tax treaties, Austria has signed many protocols for exchange information with: Andorra, Gibraltar, Monaco and ST Vincent and Grenadine. The aim of these protocols is preventing the frauds and the tax avoidance by providing information regarding the companies who wants to beneficiate from the double tax treaties.