Austria MOF Clarifies Taxation of Deemed Waived Salary for Company’s Managing Director, Shareholder

The Austrian Federal Ministry of Finance Feb. 25 posted online Federal Finance Court Decision No. RV/1100214/2023, clarifying the taxation of deemed waived salary for a company’s managing director and shareholder. The taxpayer, a 100 percent shareholder and sole managing director of multiple Austrian, German, and Swiss companies, claimed permanent waiver of all managing director remuneration, resulting in no taxable income having been accrued. The Tax Office, however, assessed income accordingly based on available evidence. On appeal, the Federal Finance Court found that: 1) the taxpayer was treated as having received the remuneration because it was booked as an expense, credited ...