Austria

Transfer Pricing in Austria

Austrian transfer pricing (Verrechnungspreise) for tax year 2026: Austrian companies and permanent establishments dealing with related companies abroad. Covers the arm's length rule in § 6 Z 6 EStG and treaty Article 9, hidden distributions under § 8(2) KStG and the KESt that follows (27.5%, or 23% for a company shareholder, grossed up when the company bears it), the VPR 2021 guidelines (methods, low value-adding services at cost plus 5%, financing), the VPDG master file and local file above EUR 50m revenue in both preceding years, country-by-country reporting at EUR 750m, fines up to EUR 50,000, § 118 BAO rulings (fee EUR 1,500 to 20,000), APAs, MAP and the EU-BStbG.