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Austrian corporate taxation

Austrian corporate income tax: what the 23% rate actually means.

Austria taxes corporate profit at a flat 23%. The real result needs a second question: what is taxable profit — and what happens when the money leaves the company?

Updated Jul 2026Current position
12 minReading time
23% flatStandard rate
GmbH · FlexCo · AGRelevant for
The central rule

Austria taxes accounting profit only after it becomes taxable income.

The annual financial statements are the starting point, not the final calculation. Tax adjustments may add back non-deductible expenditure, recognise different depreciation, restrict losses or exempt certain participation income. The result is the base to which the 23% rate applies — and the rate taxes the company's profit, not necessarily the shareholder's final result.

From €100 profit to the shareholder

The 23% is the first cut, not the whole story

A simplified example: €100 of taxable corporate profit, distributed directly to an individual shareholder taxed at the standard 27.5% capital-income rate. Treaty relief, foreign tax and corporate-shareholder exemptions can change this.

Simplified individual-shareholder example · € · of €100 profit
Company profittaxable base
100%
€100.00
€23.00 corporate income tax at 23%
After corporate taxretained by company
77%
€77.00
€21.18 distribution tax at 27.5% of €77
To the shareholderafter distribution
55.8%
€55.83
44.18%combined arithmetic burden

Illustrative only. This does not determine any particular shareholder's position — a double-tax treaty, EU directive, participation exemption, refund procedure or foreign tax may alter the outcome. If profit is retained rather than distributed, only the 23% company-level tax applies until a distribution is made.

The rate, recently

A flat rate that stepped down

The corporate rate is not progressive — it does not rise with profit. It was reduced in two steps.

25%
until 2022previous rate
24%
2023first step
23%
from 2024current
23%Flat corporate income tax
75%Max loss offset in profitable years
€500Minimum annual tax (GmbH / FlexCo)
The bridge

From accounting profit to taxable income

Taxable income is not the year-end bank balance. It starts from the accounting result and applies Austrian tax rules. A conceptual map, not a tax return.

A
Accounting resultAnnual profit or loss in the financial statements — revenue, payroll, services, depreciation, financing.
+
Tax add-backsNon-deductible or restricted expenditure, private / shareholder benefits, unsupported related-party costs.
±
Timing & valuationDepreciation, provisions, accruals, asset valuations where accounting and tax treatment differ.
Exempt / relieved incomeCertain participation income, treaty relief or other statutory exemptions, where conditions are met.
Permitted loss useCurrent and carried-forward losses — carryforwards generally capped at 75% of a profitable year.
=
Taxable corporate incomeThe base to which the flat 23% rate is applied.
01 · Minimum tax & residence

A floor on the tax, and a test on where you are managed

Companies with share capital can owe minimum corporate income tax even in a loss year. The formula is 5% of one quarter of the statutory minimum capital per full quarter — for a GmbH or FlexCo on €10,000, that is €125 per quarter, €500 for a full year.

Residence has two separate tests. The registered office is the formal location; the place of management is where decisive management decisions are actually made. An Austrian address does not make management conduct abroad irrelevant — board practice, director location, authority, contracts and substance should be consistent with the intended tax position.

The minimum-tax math

€10,000 minimum capital × 5% = €500 per year (€125 × 4 quarters). It applies even at a loss — the precise figure can depend on formation date, legal form and transitional rules.

02 · Losses in profitable years

A tax loss can survive — but may not wipe out next year's profit

Austria permits corporate loss carryforwards, but the 75% limitation means part of a profitable year can remain taxable even with larger historic losses. Example: €400,000 current profit against €500,000 of carried losses.

€300,000 offset by losses (max 75%)
€100,000 still taxable
Offset at the 75% cap Remains taxable at 23% (≈ €23,000) unused €200,000 losses carry forward

Historic losses are not an unrestricted tax asset: reconcile them with filed assessments, separate accounting losses from tax losses, and review reorganisations and ownership changes that can restrict use.

03 · Retain, distribute, and everything else

After the 23%, the route the profit takes decides the rest

Retained earnings are not taxed again merely for sitting on the balance sheet. A second level of tax generally arises on distribution — 27.5% for an individual under the standard capital-income regime; a foreign shareholder's position depends on withholding exemptions, treaty rates, refunds and home-country tax; and a corporate shareholder may qualify for participation relief. A holding analysis should never use the individual-shareholder example as its model.

Foreign income can be taxable for an Austrian-resident company, with treaty relief through exemption, credit or reduced withholding — but the treaty allocates taxing rights, it does not replace domestic analysis. And the 23% is never the whole burden: VAT, wage tax, social security, employer contributions and municipal tax can arise even when profit is low. Plan those cash flows separately, not from one general "tax reserve".

04 · The tax calendar

Quarterly prepayments, one annual assessment

15.02
Q1 prepayment

Prepayment based on the applicable assessment and forecast.

15.05
Q2 prepayment

Check whether expected annual profit still supports the assessed level.

15.08
Q3 prepayment

Mid-year accounts can flag an expected balance before year-end.

15.11
Q4 prepayment

The final quarterly payment precedes closing and the annual assessment.

Annual return

Generally due 30 April of the following year for paper filing, or 30 June for electronic filing via FinanzOnline. Represented taxpayers may receive longer filing periods.

Year-end tax review

Ten questions before the annual return

A clean position begins with the bookkeeping, contracts and shareholder transactions recorded throughout the year — not reconstructed in April.

01

Where was the company actually managed?

02

Are all material expenses supported?

03

Were shareholder payments classified correctly?

04

Are related-party prices defensible?

05

Does the asset register match tax depreciation?

06

Are carried-forward losses confirmed against assessments?

07

Was foreign tax withheld — and is relief documented?

08

Will profit be retained or distributed?

09

Do prepayments match the current forecast?

10

Are the accounts and tax return aligned?

Information, not tax advice. Rates, reliefs, minimum tax and filing rules depend on your facts and can change; the €100 example and the loss figures are simplified illustrations. Confirm the position with a licensed Austrian tax adviser before acting.
Model the tax flow

Model the tax flow before choosing how the company earns and distributes profit

Send the ownership structure, expected revenue, operating costs, financing, countries, management location and intended use of earnings. We identify the Austrian formation and structuring workstreams and coordinate tax-specific questions with a licensed adviser.