GloBE Country Guide: Austria

2026 consultation proposal (not enacted). The Ministry of Finance’s Abgabenänderungsgesetz 2026 (148/ME) was received by Parliament on October 22, 2026; consultation closes November 3. Article 3 proposes a Simplified ETR Safe Harbour (§53a), Side-by-Side and UPE safe harbours (§§56a–56b), substance-based tax incentive relief (§56c), and related reporting, transition and payment amendments. The enacted legislation below remains the baseline.

Proposed change only: Article 3, items 18 and 20 (§77(1), proposed §84(11)) would move the preliminary-return and payment date from December 31 to December 15 of the second calendar year following the preliminary-return period, first for periods from 2026. The explanatory notes, item 18 give December 15, 2028 for the 2026 period; the existing December 31 timetable for 2024 and 2025 periods is retained. This does not change the separate GIR deadlines.

Proposed additions, not current law: Article 3, items 6–13 would add Simplified ETR, Side-by-Side, UPE and substance-based tax incentive safe harbours. The Side-by-Side reduction is confined to IIR/UTPR; the UPE reduction is confined to UTPR in the UPE jurisdiction. Austrian domestic minimum tax remains applicable. Detailed eligibility and elections would still need to be met.

Draft timing requires care: item 10 changes the CbCR end-date limit to before July 1, 2029 and adds a 17% reference rate for 2027, but does not replace the current December 31, 2026 start-date cutoff. Also, §56a(1) says financial years beginning after December 31, 2025, whereas its explanatory note refers to after December 31, 2026. These inconsistencies require confirmation in the final text; a completed 2027 CbCR extension or settled Side-by-Side commencement should not be assumed from this draft.