Austria: GloBE Reporting Obligation until 31. December 2024

According to the implementation of the EU directives on the global minimum tax into Austrian law, Austrian business units of a corporate group falling under the GloBE regulations must submit an annual minimum tax report and a preliminary notification of the self-assessment levy for fiscal years from 2024, with these obligations first due in 2026.

However, in case of more than one Austrian business unit not every business unit is liable to report. Rather, a taxpayer must be determined for this purpose. The determination of the taxpayer can be made by the ultimate parent company. If no such assignment is made, the top Austrian business unit in the group structure is considered as taxpayer. If no top business unit can be identified, such as in the case of sister companies, the economically most significant Austrian business unit is used.

If, in the case of several business units located in Austria, a business unit is to be appointed as the taxpayer by the ultimate parent company, this must be reported electronically via the FinanzOnline portal in the case of fiscal years with a regular balance sheet date until 31. December 2024. If no assignment is made and thus the top Austrian business unit or, in the absence of such determinability, the economically most significant business unit is the taxpayer, no notification is required. Likewise, no notification is required if only one business unit of the corporate group is resident in Austria anyway.

We are happy to support you in cooperation with our colleagues from RSM Austria in examining whether an assignment by the ultimate parent company should take place. Please feel free to contact your RSM Ebner Stolz contact for this purpose.