Is any withholding tax imposed on dividends paid by a locally resident company to a non-resident?
Under Austrian national tax law, dividends are subject to a 25% dividend withholding tax. This withholding tax is reduced by most tax treaties. In addition, no withholding tax will be imposed at source on intra-group dividends to EU resident parent corporations, in compliance with the EC Parent Subsidiary Directive, if the following requirements are met: · the parent company directly and continuously holds at least 10% (in some countries 25% is required under the principle of reciprocity) in the distributing Austrian company for a period of one year; · the Austrian company is in the legal form of an AG or a GmbH, i.e. a corporation; · the parent company is a corporation as listed in Art. 2 of Directive 90/435/EC; · the parent corporation provides a residency certificate issued by the foreign tax authorities which is issued within one year before or after the dividend is paid; and · the parent company provides confirmation to its subsidiary that it has active business income, employees
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