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11. BUSINESS TRANSFORMATION AND RE-ORGANIZATION

Exit taxes are triggered in respect of capital gains when Austria loses taxation rights on a taxpayer’s respective sources of income due for example to termination of Austrian residence, etc. Austria provides a facility to pay the exit tax in installments in cases where Austrian business assets are transferred to an EU or EEA Member State with which Austria has entered into an information exchange and enforcement agreement. If such an option is elected, installments are made over 5 years for fixed assets (reduced from 7 years effective 1 January 2019) and 2 years for current assets. If the assets are subsequently transferred to a non-EU/EEA country, the outstanding amount of exit tax becomes due.