Pillar 2 – Österreich: Global Comparison of Pillar 2 Implementation — Insights and Strategies for Harmonization – Country Report: Austria

Abstract Austria implemented the OECD/G20 Global Anti-Base Erosion Model Rules (Pillar II) through the Minimum Tax Reform Act (MinBestRefG, BGBl. I 187/2023), effective 31 December 2023. The legislation introduced the Income Inclusion Rule (IIR), the Undertaxed Profits Rule (UTPR), and an elective Qualified Domestic Minimum Top-Up Tax (QDMTT). Implementation follows Austria’s civil law principles, requiring statutory precision and limiting automatic dynamic references to external norms such as de GloBE Model Rules. This report analyzes national particularities, which include the treatment of governmental entities, the non-neutral taxation of equity gains and losses, and the research premium as a Qualified Refundable Tax Credit. While fiscal effects forecast a rather minor budgetary implication, the reform primarily reflects Austria’s commitment to international tax harmonization and the establishment of a global minimum tax framework.