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Austria

In: Intangibles in the World of Transfer Pricing

Author

Listed:
  • Karin Andorfer

    (Deloitte)

  • Andreas Gregshammer-Salomon

    (Deloitte)

Abstract

In Austria, the arm’s length principle is implemented in several provisions of the (corporate) income tax law. Whereas Section 6 item 6 Austrian Income Tax Act (ITA) generally implements the arm’s length principle for cross-border transactions between related parties, Section 8 para 1 and para 2 Austrian Corporate Income Tax Act (CITA) concerning hidden capital contribution and hidden profit distribution specify that transactions between corporations and their shareholders have to be at arm’s length terms to be recognized for tax purposes. Whereas in cross-border transactions, the tax administration generally refers to Section 6 item 6 ITA when assessing transfer prices as primary adjustment, Section 8 paras 1 and 2 might give rise to secondary adjustment.

Suggested Citation

  • Karin Andorfer & Andreas Gregshammer-Salomon, 2021. "Austria," Springer Books, in: Björn Heidecke & Marc C. Hübscher & Richard Schmidtke & Martin Schmitt (ed.), Intangibles in the World of Transfer Pricing, edition 1, pages 369-390, Springer.
    • Handle: RePEc:spr:sprchp:978-3-319-73332-6_23
    DOI: 10.1007/978-3-319-73332-6_23
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