Austria MOF Clarifies Taxation of Installment Payments for Property Sale Arrangement Under Arm’s-Length Principle

The Austrian Federal Ministry of Finance June 12 posted Federal Finance Court Decision No. RV/2100182/2025, clarifying the taxation of installment payments in a property sale arrangement, according to the arm’s-length. The taxpayer, an individual, sold a property to relatives at a reduced price with a long-term installment plan and minimal annual payments. The tax authorities assessed real estate income tax for the year of the transaction. On appeal, the Federal Finance Court found that: 1) income from private sales is generally taxed upon receipt, but installment arrangements must reflect arm’s length conditions to be recognized; 2) the agreed payment structure, ...