Austria · Guide
The six cases where Austria bars relief at source
An Austrian payer may apply a treaty rate when it pays instead of deducting in full. One paragraph lists the cases where it may not. This article works through all of them, the documentation behind them, and the route the recipient is left with.
Updated 18 September 2026. Every provision below was read that day in the consolidated text the Bundeskanzleramt publishes as open data, with its paragraph, its gazette reference and the date it took effect.
Relief at source runs under the DBA-Entlastungsverordnung, BGBl. III Nr. 92/2005. Its § 5 Abs. 1 lists the cases in which relief at source is inadmissible, and in the version in force from 1 September 2022 six of them are live: Z 1, Z 2, Z 3, Z 5, Z 6 and Z 7. Z 4 was repealed. A seventh prohibition sits in § 5 Abs. 2, outside the numbered list.
- A permission, not a right, and the payer carries it
- The six cases, in the words of the ordinance
- Z 1, the bar that points at three other paragraphs
- The three bars that look at the recipient
- Z 3, Z 7, and the prohibition below the list
- Where the labour-hire bar went
- What the payer does when a bar applies
- The route that is left
- The same three facts, asked twice
- What has changed since 2005
- Where this page stops
- Sources
- FAQ
A permission, not a right, and the payer carries it
The ordinance hands the decision to the Austrian payer, and the risk with it. § 1 says that where income of a person resident abroad is to be relieved of an Austrian deduction in whole or in part under a double taxation convention, the relief may be brought about by the payer of the fee, in direct application of the convention. The next sentence is the one that costs money: the payer is then obliged "die Richtigkeit der Unterlassung oder Einschränkung des Steuerabzuges zu beweisen oder nach Maßgabe des § 138 BAO glaubhaft zu machen", to prove that omitting or limiting the deduction was right, or to make it credible under BAO § 138. The benefit belongs to the recipient; the file belongs to the company.
Three decisions fix what that means. In 2009/15/0090 of 24 June 2009 the Verwaltungsgerichtshof said the ordinance defines the conditions under which relief may be given at source. In 2009/15/0175 of 26 February 2013, VwSlg 8788 F/2013, it drew the consequence: where domestic law imposes a duty to remit, the deduction under EStG § 99 may be left undone only if all the ordinance's conditions for relief at source are met. And in Ra 2019/15/0095 of 10 May 2021 it confined the procedure to recipients resident abroad. What Austria deducts, from whom and by when is on the withholding tax guide; this page is about the paragraph that closes the shortcut.
The six cases, in the words of the ordinance
§ 5 Abs. 1 opens with one sentence and then numbers its cases: "Eine Entlastung an der Quelle ist in folgenden Fällen unzulässig", relief at source is inadmissible in the following cases. In the version in force from 1 September 2022 the numbering runs 1, 2, 3, 5, 6, 7, and the gap is not a typesetting error. The consolidated text prints, in place of the old fourth case, "(Anm.: Z 4 aufgehoben durch Art. 2 Z 1, BGBl. II Nr. 318/2022)".
| Ziffer | What the ordinance provides | What it turns on |
|---|---|---|
| Z 1 | the documentation requirements of §§ 2 to 4 are not sufficiently met | the file the payer holds, and nothing about the recipient |
| Z 2 | the income is not attributable to the foreign recipient for tax purposes, and the payer knows this or on the care of a prudent merchant should have known it | who the income belongs to, tested against what the payer ought to have seen |
| Z 3 | a fee for an activity within EStG § 99 Abs. 1 Z 1 is paid to a third party rather than to the person who performed it, and there are no documents giving that person's name and address and the amounts flowing to them | who is paid, and what the payer can evidence about the performer |
| Z 5 | the recipient is a foreign foundation, a foreign trust or a foreign investment fund | the legal form of the recipient, with no further test |
| Z 6 | the recipient is a legal person whose place of actual management is not in its state of incorporation | where the recipient is really run |
| Z 7 | capital yields are paid out, at maturity or on a sale of securities, by credit institutions acting as custodian or administrator of securities | who hands the money over, not who receives it |
Two features matter before the cases are taken one at a time. This is a list of cases, not of taxpayers: three of the six turn on the payer's file, on who is paid and on who hands the money over, and only two on what the recipient is. And the list is absolute. Nothing in § 5 gives the tax office a discretion to allow relief at source anyway, and nothing in it turns on what the convention provides.
The six live cases of DBA-Entlastungsverordnung § 5 Abs. 1, in force from 1 September 2022 (BGBl. III Nr. 92/2005 as amended by BGBl. II Nr. 318/2022), read at source on 18 September 2026. Z 4 was repealed with effect from the end of 31 August 2022.
Before a payment leaves Austria
Tell us what the payment is for, who receives it and in which state that recipient is resident. We will set out what the ordinance requires to be held, which of its cases the payment falls to be tested against, and where the answer is reserved to a licensed Austrian Steuerberater.
Z 1, the bar that points at three other paragraphs
Z 1 is the widest of the six because it has no content of its own. It bars relief at source where the documentation requirements of §§ 2 to 4 are not sufficiently met, so everything those three paragraphs ask for becomes a condition of the relief.
§ 2 Abs. 1 is the starting point: entitlement to the convention may be made credible in principle by a residence certificate from the foreign tax administration on form ZS-QU1 for an individual or ZS-QU2 for a legal person. Abs. 2 opens a smaller door: where payments to a single recipient do not exceed EUR 10,000 in the calendar year and that recipient has no dwelling in Austria, a written declaration carrying the seven particulars it lists may make the entitlement credible instead. The Verwaltungsgerichtshof read the two limbs together in Ra 2023/15/0066 of 9 October 2024: nothing in Abs. 1 says the certificate may be issued only on those forms, but because Abs. 2 lets a declaration replace a certificate below EUR 10,000, above EUR 10,000 a certificate must in principle be produced.
§ 3 Abs. 1 adds a second document where the recipient is a legal person, or a partnership treated as one abroad: a declaration that it carries on an activity going beyond the bounds of asset management, "eine Betätigung entfaltet, die über den Rahmen der Vermögensverwaltung hinausgeht", that it employs its own staff and that it has its own business premises. Abs. 2 offers one substitute and only one: evidence that within the last three years the tax authority granted that recipient a treaty-conform refund application on payments by the same payer. § 4 takes a partnership treated as transparent abroad, and asks for a ZS-QU1 or ZS-QU2 from each partner whose share of the relieved fees exceeds EUR 10,000 in the calendar year (§ 4, third sentence).
The ordinance names no company type anywhere in that chain. What it asks about a legal person is activity, staff and premises, and a recipient that cannot make those three declarations fails § 3 and is barred by Z 1, whatever it is called. An Austrian Privatstiftung is a different subject and is on the private foundation guide.
DBA-Entlastungsverordnung · the documentation Ziffer 1 points at
- § 2 Abs. 1
Residence certificate
Issued by the foreign tax administration on form ZS-QU1 for an individual or ZS-QU2 for a legal person.
- § 2 Abs. 2
Or a written declaration, below EUR 10,000
Payments to that one recipient not exceeding EUR 10,000 in the calendar year, and no dwelling in Austria: a declaration carrying the seven particulars the paragraph lists.
- § 3 Abs. 1
A legal person declares three more things
Activity going beyond the bounds of asset management, its own staff, its own business premises.§ 3 Abs. 2, the only substitute: evidence that a treaty-conform refund application of that recipient, on payments by the same payer, was granted within the last three years.
- § 4
A partnership treated as transparent abroad
ZS-QU1 or ZS-QU2 for each partner whose share of the relieved fees exceeds EUR 10,000 in the calendar year; names and addresses kept on record for the others.
§ 5 Abs. 1 Z 1Where the documentation requirements of §§ 2 to 4 are not sufficiently met, relief at source is inadmissible.
BGBl. III Nr. 92/2005 · read at source 18 September 2026
The three bars that look at the recipient
Z 2, and what the payer is taken to have known.
The bar applies where circumstances are known to the payer, or on the care of a prudent merchant ought to have been known, showing that the income is not attributable to the foreign recipient for tax purposes: "bei Anwendung der Sorgfalt eines ordentlichen Kaufmannes hätten bekannt sein müssen". It is not a test of what the payer believed, but of what a merchant exercising ordinary care in that trade would have seen, so complete paperwork does not answer it. What a nominee arrangement may and may not do in Austria is on the nominee director guide.
Z 5, three legal forms and no further test.
Where the recipient is a foreign foundation, a foreign trust or a foreign investment fund, relief at source is inadmissible. The paragraph asks nothing about substance, about the convention or about who stands behind the structure. The form of the recipient decides it.
Z 6, incorporation in one state and management in another.
Where the recipient is a legal person whose place of actual management is not in its state of incorporation, relief at source is inadmissible. That is not the same question as whether the recipient is resident under the convention, and a residence certificate does not answer it. Where a company is managed is also what decides Austrian corporate residence, which is on the corporate tax guide.
Z 3, Z 7, and the prohibition below the list
Z 3 and Z 7 turn on the payment rather than on the recipient's form or residence, and § 5 Abs. 2 adds a prohibition that sits outside the numbered list altogether.
Z 3 is about a fee that reaches a third party. EStG § 99 Abs. 1 Z 1 catches fees for the activity of writers, lecturers, artists, architects, sportspeople, artistes and participants in entertainment. Where such a fee is paid not to the performer but to a third party, and there are no documents giving that person's name and address and the amounts flowing to them, relief at source is inadmissible. The documents are the whole of it, which is why routing a fee through an agency neither triggers the bar by itself nor escapes it by itself.
Abs. 2 takes the case where the documents exist. It is written as a permission and ends as a bar: the deduction may be limited to the part of such a fee that flows on to the performer, and "für diesen Teil ist eine Entlastung an der Quelle auf Grund von Doppelbesteuerungsabkommen unzulässig", for that part relief at source on the basis of double taxation conventions is inadmissible. So the paragraph carries six prohibitions in its numbered list and a seventh immediately below it.
Z 7 is about who hands the money over. Where capital yields are paid out at maturity, or on the occasion of a sale of securities, by credit institutions acting in their function as custodian or administrator of securities, relief at source is inadmissible. Nothing in that sentence looks at the recipient, the convention or the file. A dividend on a custodied holding is outside the relief-at-source system by design, so the same dividend paid by the Austrian company itself and paid through a custodian are not the same case.
Where the labour-hire bar went
The repealed Z 4 declared relief at source inadmissible for fees for the hiring out of labour for work in Austria, except for an intra-group posting of salaried staff, and the Verwaltungsgerichtshof applied it in that form in Ro 2017/13/0007 of 17 July 2019, read together with the exemption decision the old § 5 Abs. 3 allowed. Both provisions ceased to have effect at the end of 31 August 2022, which is worth knowing before that decision is read.
The subject did not leave the law, it moved. Article 1 of the same gazette, BGBl. II Nr. 318/2022, made a separate ordinance for the hiring out of labour. Its § 3 Abs. 1 applies §§ 1 to 6 of the DBA-Entlastungsverordnung to relief at source in those cases, and its § 3 Abs. 2 then permits relief at source only in the cases it lists: an intra-group posting of salaried staff where 70 percent of the deduction on the hire fee is withheld and remitted under its § 1, or wage tax is deducted for the posted workers, and otherwise only on a time-limited decision of the Finanzamt für Großbetriebe. What that buys is on the withholding tax guide.
What the payer does when a bar applies
Deduct in full.
A bar removes the shortcut, not the charge: the domestic deduction applies at the domestic rate and the convention is given effect afterwards. The rates and the paragraphs that set them are on the withholding tax guide.
Remit on the ordinary calendar.
Capital yields tax runs on the EStG § 96 Abs. 1 timetable, the deduction under EStG § 99 to the 15th day after the following calendar month under EStG § 101 Abs. 1. Nothing in the ordinance moves either date.
File the notification, whatever was decided.
EStG § 96 Abs. 3 requires the electronic notification in the same period, and expressly requires it even where no deduction is to be made, with the reason given; the deduction under EStG § 99 carries its own notification under EStG § 101 Abs. 3. A payer that relieved at source has a filing. A payer that was barred has the same filing and a payment.
Certify it to the recipient.
EStG § 96 Abs. 4 obliges the withholding agent to certify the income, the tax, the day of payment, the period and the office it went to. Without that certificate the recipient cannot begin the route below.
The route that is left
Where tax was deducted and a convention says it should not have been, the money comes back through the refund in the Bundesabgabenordnung, and three of its sentences decide whether it does.
Five years, and the treaty cannot shorten them. BAO § 240 Abs. 3 lets the taxpayer apply for repayment of an amount wrongly withheld until the end of the fifth calendar year following the year of withholding, and refuses it so far as an assessment has been made, has to be made, or would have to be made on an application for assessment. Abs. 4 gives a refund based on a convention the same period "ungeachtet allfälliger im Abkommen vereinbarter kürzerer Fristen", notwithstanding any shorter periods the convention itself agrees, and allows one year from notification of a decision under BAO § 48 Abs. 2 or Abs. 4 where the claim rests on one, regardless of limitation.
A sentence that ties the refund back to the payer. Abs. 4 closes with the condition that decides who carries a failed relief at source: "Im Haftungsweg nachgeforderte Beträge sind nur insoweit rückzuzahlen, als sie dem Abzugsverpflichteten ... vom Abgabepflichtigen ersetzt wurden". Amounts recovered from the withholding agent by way of its liability are repayable only so far as the taxpayer has reimbursed that agent. A company assessed years later, which never recovered the tax from the recipient, therefore faces a recipient whose refund is capped at what was actually paid back.
Nothing can be applied for until the year is over. BAO § 240a Abs. 1 requires a limited taxpayer to file an electronic advance notification first, and says it is not admissible until the year of withholding has ended. Abs. 2 closes every other form: the application can be made exclusively by the printed advance notification carrying its transmission confirmation, signed, and completed with the residence certificate of the foreign tax administration. The content and procedure are in an ordinance of their own, BGBl. II Nr. 22/2019, whose § 2 puts the notification on the web forms published on the Federal Ministry of Finance website and allows German or English, and whose § 4 has the mechanics: the form is filed electronically, a document carrying a generated transaction number is produced and made available to the applicant, and that document is what the BAO § 240a Abs. 2 application uses.
When a case in § 5 applies · the route that is left
Relief at source inadmissible
One of the six cases in the numbered list, or the prohibition in Abs. 2.§ 5 Abs. 1 and Abs. 2
The payer deducts, remits and files
The domestic deduction at the domestic rate, on the ordinary calendar, with the notification and the certificate.EStG §§ 96 and 101
The year of withholding ends
An advance notification is not admissible before it.BAO § 240a Abs. 1
Electronic advance notification
On the ministry’s web forms, in German or in English; a transaction number is generated.BGBl. II Nr. 22/2019 §§ 2 and 4
The application, and only this way
The printed advance notification with its transmission confirmation, signed, plus the foreign residence certificate.BAO § 240a Abs. 2
The deadline on stations 04 and 05To the end of the fifth calendar year following the year of withholding, and for a refund based on a convention notwithstanding any shorter period the convention itself agrees. BAO § 240 Abs. 3 and Abs. 4.
Read at source 18 September 2026
The same three facts, asked twice
The two procedures are usually set out as alternatives. On the substance questions they are one procedure asked at two moments.
§ 3 Abs. 1 of the DBA-Entlastungsverordnung asks a legal person seeking relief at source to declare activity beyond asset management, own staff and own business premises. The ordinance governing the refund asks the same three. Its § 3 sets out what an advance notification must contain by category of income, and in each category the questions put to a legal person are the extent of the business activity in Austria, the employment of staff, the existence of business premises and the shareholding structure of the applicant: Abs. 1 Z 8 lit. g to lit. j for capital yields tax, Abs. 2 Z 5 to Z 8 for royalties within EStG § 99, Abs. 3 Z 4 to Z 7 for other deductible payments. And § 3 Abs. 2 of the DBA-Entlastungsverordnung closes the loop: a refund application granted in the last three years stands in for the substance declaration at source.
What has changed since 2005, and what has not
The ordinance has been amended three times in twenty-one years. The cases have been six since 1 September 2022 and were seven before that.
| Gazette | In force | What it did |
|---|---|---|
| BGBl. III Nr. 92/2005 | 1 July 2005 | the ordinance as made: § 5 Abs. 1 with seven Ziffern and § 5 Abs. 2, and § 6 Abs. 2 disapplying eleven implementing ordinances made under named conventions |
| BGBl. II Nr. 44/2006 | 4 February 2006 | inserted § 5 Abs. 3, the exemption decision that let the tax office allow relief at source in a labour-hire case |
| BGBl. II Nr. 579/2020 | 1 January 2021 | replaced the office named in § 5 Abs. 3 with the Finanzamt für Großbetriebe (§ 6 Abs. 4) |
| BGBl. II Nr. 318/2022 | 1 September 2022 | repealed § 5 Abs. 1 Z 4 and § 5 Abs. 3 with effect from the end of 31 August 2022, deleted the spent § 6 Abs. 2, made the labour-hire ordinance in its Art. 1 and repealed the eleven implementing ordinances in its Art. 3 |
Two things in § 6 are easy to conflate and are different instruments. The eleven items the 2022 gazette repealed are Durchführungsverordnungen, implementing ordinances made under conventions with Belgium, Brazil, the CSSR, Great Britain, Ireland, Canada, the Netherlands, Poland, Portugal, Spain and Hungary; the ordinance had disapplied them for Austrian relief purposes in its own § 6 Abs. 2 since 2005, which is why that subsection was deleted as spent. What survives is § 6 Abs. 3, five Durchführungsvereinbarungen, implementing agreements with Denmark, Liechtenstein, Luxembourg, Sweden and Switzerland, of which the ordinance says "stehen der Anwendung des Systems der Entlastung an der Quelle nach dieser Verordnung nicht entgegen": they do not stand in the way of applying the relief-at-source system under this ordinance.
The amendment history as the consolidated text records it, read on 18 September 2026 at § 6 of the ordinance and in the gazetted text of BGBl. II Nr. 318/2022. A query for a version of any paragraph with a commencement date in the future returned none.
Where this page stops
Every provision above carries its paragraph, its Bundesgesetzblatt reference and the date its version took effect, and each was read on 18 September 2026 in the consolidated document the Bundeskanzleramt publishes as open data. The German inside quotation marks is the ordinance's own; the English beside it is ours.
What this page does not do is apply any of it to a reader. It states which cases the ordinance names and what it requires; it does not say whether a particular payment, recipient or file falls inside one of them. In Austria advice on a tax position, book-keeping and representation before the tax authorities are reserved to a licensed Steuerberater under WTBG 2017 § 2 Abs. 1, and § 124 Abs. 1 Z 1 makes offering the reserved work an offence in itself. No treaty rate appears here either, because which convention applies and what it allows is a question for that convention. What is reserved on the Austrian side is on the tax advisory guide; who we are is on about us.
Sources
Read on 18 September 2026 at the Bundeskanzleramt's open data. Each document number was checked against the paragraph label and the gazette reference printed in that document.
- DBA-Entlastungsverordnung, BGBl. III Nr. 92/2005 (Gesetzesnummer 20004176): the instrument and its long title at § 0 · § 1
NOR40065884· § 2NOR40065885· § 3NOR40065886· § 4NOR40065887· § 5NOR40246888· § 6NOR40246890 - Superseded versions of § 5, consulted for the repealed Z 4 and Abs. 3:
NOR40065888(1 July 2005 to 3 February 2006),NOR40074888(to 31 December 2020),NOR40230706(to 31 August 2022) - Bundesabgabenordnung: § 240
NOR40246319· § 240aNOR40246320 - Vorausmeldungsverordnung, BGBl. II Nr. 22/2019 (Gesetzesnummer 20010560): the instrument and its long title at § 0 · § 2
NOR40212442· § 3NOR40230720· § 4NOR40212444 - DBA-Durchführung-Anpassungsverordnung, BGBl. II Nr. 318/2022, gazetted text:
BGBLA_2022_II_318 - Verwaltungsgerichtshof: Ra 2023/15/0066 of 9 October 2024
JWR_2023150066_20241009L01· Ro 2017/13/0007 of 17 July 2019JWR_2017130007_20190717J01· 2009/15/0175 of 26 February 2013JWR_2009150175_20130226X01· 2009/15/0090 of 24 June 2009JWR_2009150090_20090624X02· Ra 2019/15/0095 of 10 May 2021JWR_2019150095_20210510L03
Frequently asked questions
What is relief at source in Austria?
It is the procedure in the DBA-Entlastungsverordnung, BGBl. III Nr. 92/2005, by which the Austrian payer applies a double taxation convention when it pays, instead of deducting in full and leaving the recipient to reclaim. Its § 1 makes this something the payer may do rather than must do, and then obliges the payer to prove, or make credible under BAO § 138, that omitting or limiting the deduction was correct.
In how many cases does the ordinance bar relief at source?
Six, read at source on 18 September 2026. § 5 Abs. 1 numbers its cases 1, 2, 3, 5, 6 and 7, and the gap is real: Z 4 was repealed by Art. 2 Z 1 of BGBl. II Nr. 318/2022 and ceased to have effect at the end of 31 August 2022. A seventh prohibition sits outside that list, in § 5 Abs. 2.
What are the six cases?
Documentation under §§ 2 to 4 not sufficiently met (Z 1); income not attributable to the foreign recipient, where the payer knew or on a prudent merchant's care should have known (Z 2); a fee within EStG § 99 Abs. 1 Z 1 paid to a third party with no documents naming the performer and the amounts reaching them (Z 3); a foreign foundation, trust or investment fund as recipient (Z 5); a legal person whose place of actual management is not in its state of incorporation (Z 6); and capital yields paid out by a credit institution acting as custodian or administrator (Z 7).
What documents does the Austrian payer have to hold?
A residence certificate from the foreign tax administration on form ZS-QU1 for an individual or ZS-QU2 for a legal person (§ 2 Abs. 1). Below EUR 10,000 a year to one recipient with no Austrian dwelling, the declaration with the seven particulars in § 2 Abs. 2 may take its place. A legal person adds the declaration in § 3 Abs. 1 on activity beyond asset management, own staff and own premises.
Is form ZS-QU1 or ZS-QU2 the only way to prove residence?
The Verwaltungsgerichtshof held in Ra 2023/15/0066 of 9 October 2024 that § 2 Abs. 1 does not say the certificate can be issued only on those forms. The same decision reads § 2 Abs. 2 the other way round: because a declaration may replace a certificate below EUR 10,000, above EUR 10,000 a residence certificate must in principle be produced.
Is there any substitute for the substance declaration in § 3?
§ 3 Abs. 2 allows one, and names it: evidence that within the last three years the tax authority granted that recipient a treaty-conform refund application in respect of payments by the same payer. Nothing else is offered in the text, and Z 1 bars relief at source where the documentation requirements of §§ 2 to 4 are not sufficiently met.
Why can a custodian bank not give relief at source on a dividend?
Because § 5 Abs. 1 Z 7 says so. Where capital yields are paid out at maturity, or on a sale of securities, by a credit institution acting as custodian or administrator of securities, relief at source is inadmissible, whatever the convention provides and however complete the file is.
What does the payer do when one of the bars applies?
It deducts the domestic tax in full and runs the ordinary machinery: remittance and the electronic notification for capital yields tax under EStG § 96, or by the 15th day after the following calendar month with a separate notification for the deduction under EStG § 99, and a certificate to the recipient. The rates and the calendar are on the withholding tax guide.
How does the recipient get the money back, and by when?
By applying for a refund. BAO § 240 Abs. 3 runs to the end of the fifth calendar year following the year of withholding, and § 240 Abs. 4 gives a treaty refund the same five years notwithstanding any shorter period the convention agrees. Where the claim rests on a decision under BAO § 48 Abs. 2 or Abs. 4, one year from notification of it is allowed, regardless of limitation.
Can the refund be applied for straight away?
No. BAO § 240a Abs. 1 requires an electronic advance notification before the application, and it is not admissible until the year of withholding has ended. Abs. 2 closes every other route: the application is made exclusively by the printed advance notification carrying its transmission confirmation, signed, and completed with the foreign residence certificate.
Does the advance notification have to be in German?
No. The ordinance governing it, BGBl. II Nr. 22/2019, says in its § 2 that the notification is made on the web forms published on the Federal Ministry of Finance website and may be made in German or in English. Its § 4 adds the mechanics: the form is filed electronically and a document carrying a transaction number is generated, and that document is what the BAO § 240a Abs. 2 application uses.
Is relief at source available on a fee for hiring out staff to Austria?
The bar that covered it, § 5 Abs. 1 Z 4, was repealed at the end of 31 August 2022. The same gazette, BGBl. II Nr. 318/2022, made a separate ordinance for labour hire in its Art. 1, whose § 3 Abs. 1 applies §§ 1 to 6 of the DBA-Entlastungsverordnung and whose § 3 Abs. 2 then permits relief at source only in the cases it lists. What that leaves is on the withholding tax guide.
Related
Company Registration Austria: Withholding Tax in Austria (KESt) What Austria deducts on a dividend and on a payment to a non-resident, who is liable for it, and the three procedures through which a treaty reduction is claimed.
Company Registration Austria: The Austria to United States tax treaty, for a founder Which state may tax what when an American owns an Austrian company, and the article that leaves Austria's own withholding system in place.