Austria: Appointment of alternative Pillar Two taxpayer due by December 31, 2024

Proof of appointment must also be uploaded in FinanzOnline

Under the Pillar Two rules in Austria, only one constituent entity is treated as the Pillar Two taxpayer that is required to submit a preliminary declaration and pay any top-up tax. If there are multiple Austrian constituent entities, the “top” constituent entity in Austria is automatically considered to be the Pillar Two taxpayer. If there is no "top" constituent entity in Austria, the economically most significant constituent entity located in Austria is considered to be the Pillar Two taxpayer.

However, the ultimate parent entity (UPE) of a multinational group may appoint an alternative constituent entity in Austria to be the Pillar Two taxpayer in Austria. For calendar year taxpayers, the appointment of an alternative Pillar Two taxpayer in Austria must be filed with the responsible tax office by December 31, 2024. Proof of the appointment must then be uploaded in FinanzOnline.

Read an October 2024 report prepared by the KPMG member firm in Austria

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Austria: Appointment of alternative Pillar Two taxpayer due by December 31, 2024

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