Austria Corporate Tax Guide (Körperschaftsteuer 2026)
Austria's Körperschaftsteuer (KöSt) applies at a flat rate of 23% on corporate profits. The group taxation regime (Gruppenbesteuerung) allows offsetting profits and losses within a group. The participation exemption makes dividends and capital gains from qualifying shareholdings (≥10%) tax-free. Filing is electronic via FinanzOnline. All amounts in EUR (de-AT locale).
The KöSt is governed by the Körperschaftsteuergesetz (KStG) and applies to all limited liability companies (GmbH), stock corporations (AG), and other legal entities resident in Austria. Tax residents are subject to tax on worldwide income; non-resident corporations are taxed on Austrian-source income only. For related reading, see our Personal Tax Guide → and VAT Guide →.
Corporate Tax Rate and Base
- Flat 23% rate: Austria applies a single flat rate of 23% on taxable profits (Einkommen). This rate has been stable since 2023 (reduced from 25% in 2022 and 24% in 2023). There is no progressive rate structure — all corporations pay 23% regardless of profit level.
- Minimum tax (Mindestkörperschaftsteuer): Each corporation must pay a minimum tax of €500 per year (€1,000 for GmbHs). This is reduced by the amount of any positive tax liability — i.e., if the corporate tax calculated exceeds the minimum, only the higher amount is due. For the first five years after incorporation, the minimum is €0 (start-up relief).
- Taxable base: Calculated as commercial profit (Unternehmensgewinn) under the Einkommensteuergesetz rules, with specific KStG adjustments. Key adjustments include: non-deductible expenses (Strafen, penalties), participation exemption deductions, and group taxation adjustments.
- Corporate income tax return (KöSt-Erklärung): Filed electronically via FinanzOnline by June 30 of the following year (extendable to March 31 of the second following year). The tax assessment (Bescheid) is issued by the Finanzamt, and any tax due must be paid within one month of the assessment.
Group Taxation (Gruppenbesteuerung)
- Full consolidation: Austrian group taxation (Gruppenbesteuerung) allows a parent company (Gruppenträger) to offset the profits and losses of its domestic and qualifying foreign subsidiaries within a fiscal group (Unternehmensgruppe). The group is treated as a single taxpayer for tax purposes — intra-group transactions are eliminated, and losses of one entity offset profits of another.
- Eligibility: The parent must hold directly or indirectly more than 50% of the shares (voting rights or capital) in the subsidiary. Both the parent and the subsidiary must have their registered seat or place of management in Austria (for domestic group members). Foreign subsidiaries can be included if they are resident in an EU/EEA country and have their legal form listed in the KStG Annex.
- Loss offsetting: Losses of group members are allocated to the parent company. Foreign branch losses are included but may be recaptured (recaptured if the branch becomes profitable or is transferred). The parent can offset the losses against its own profits. Profits of group members are also allocated to the parent and taxed at 23%.
- Application: The group taxation election is made through a formal application (Gruppenantrag) to the Finanzamt before the start of the financial year. Once granted, the group must remain in place for a minimum of three years. Early exit may trigger retrospective adjustments.
Participation Exemption and Tax-Free Reorganisations
- Dividend exemption (Internationales Schachtelprivileg): Dividends received from a qualifying participation (≥10%) in a domestic or foreign subsidiary are tax-free at the corporate level. The exemption applies regardless of the holding period — dividends are immediately tax-free if the 10% threshold is met at the distribution date. No foreign tax credit is needed (the dividend is simply exempt).
- Capital gains exemption: Gains from the sale of shares in a qualifying participation (≥10%) are tax-free. The corresponding acquisition costs are not deductible. If the participation falls below 10%, the exemption ceases. Losses on the sale of qualifying participations are not deductible (matching the tax-free treatment of gains).
- Tax-free reorganisations (Umgründungen): The Umgründungssteuergesetz (UmgrStG) provides tax-neutral treatment for: (a) mergers (Verschmelzung), (b) demergers (Spaltung), (c) conversions (Umwandlung), (d) contributions-in-kind (Einbringung). Qualifying reorganisations can be carried out at book value — no immediate tax is triggered on unrealised gains.