Austria · Company forms
Holding Company
in Austria
The company that holds your Austrian and foreign shareholdings, in a form that fits and with a seat that holds up.
- No separate legal form: FBG § 2
- Share capital from EUR 10,000: GmbHG § 6 Abs. 1
- Court fee EUR 522 for a GmbH, from 1 August 2026
- Minimum corporate tax EUR 500 a year: KStG § 24 Abs. 4 Z 1
What an Austrian holding company actually is
Austria has no holding company. The main book of the Firmenbuch is kept for thirteen classes of entity and a holding is not among them (FBG § 2, in force from 1 January 2024). It has ordinary companies, formable for any legally permissible purpose (GmbHG § 1 Abs. 1).
So the question is not whether to register a holding, but which form holds the shares, what the state charges, which Körperschaftsteuergesetz provisions the structure can meet, and what the seat has to be. how Austrian company types compare on capital and liability sets out the forms.
What the holding service includes
The form decision.
Which of the three forms holds the shares, and what it costs at the register and each year.
Incorporation.
Articles or a declaration of establishment for the notarial deed, the capital confirmation, the Firmenbuch filing.
The registered seat.
An address that answers the GmbHG § 5 Abs. 2 test, not a nameplate. Where it would not, we say so.
Tax registration.
The tax office file, the tax account and the returns calendar, with a licensed Steuerberater where the work is reserved.
The beneficial-owner filing.
Compulsory once a company sits in the chain: the WiEReG § 6 Abs. 2 exemption ends there.
Financing documents.
Shareholder loans and acquisition debt read against KStG § 11 Abs. 1 Z 4, § 12 Abs. 1 Z 9 and § 12a.
Treaty documentation.
The residence certificate and declarations the DBA-Entlastungsverordnung wants before relief at source.
Which form the holding takes
Three forms can hold participations. These columns decide between them; formation detail is on gmbh in austria.
| Decision | GmbH | FlexCo (FlexKapG) | AG |
|---|---|---|---|
| Minimum share capital | EUR 10,000 (GmbHG § 6 Abs. 1, from 1 January 2024) | EUR 10,000 (GmbHG § 6 Abs. 1 through FlexKapGG § 1 Abs. 2) | EUR 70,000 (AktG § 7) |
| Smallest single contribution | EUR 70 (GmbHG § 6 Abs. 1) | EUR 1 (FlexKapGG § 3) | a par-value share of at least EUR 1 or a multiple of it, or a no-par share carrying at least EUR 1 of the capital; the two kinds may not exist side by side (AktG § 8) |
| Cash paid in before registration | at least EUR 5,000 in total, a quarter of each contribution and at least EUR 70 each (GmbHG § 10 Abs. 1) | a quarter of each contribution, at least EUR 1 (FlexKapGG § 5) | at least a quarter of the lowest issue amount plus the whole of any premium, contributions in kind in full (AktG § 28a); on EUR 70,000 at par that is EUR 17,500, arithmetic on the rule rather than a figure the statute states |
| Who may be a managing director | only a natural person with legal capacity (GmbHG § 15 Abs. 1) | the same, through FlexKapGG § 1 Abs. 2 | a management board |
| Supervisory board | capital over EUR 70,000 and more than 50 shareholders, both together (GmbHG § 29 Abs. 1 Z 1), plus five further limbs | the same | always |
| First registration, court fees | EUR 522 | no tariff line names it | EUR 910 |
Court fees are GGG Tarifpost 10 Z I, in force from 1 October 2026, as raised by BGBl. II Nr. 227/2026 from 1 August 2026. The FlexCo cell is empty because that tariff carries no line naming the form.
How an Austrian holding company is set up
Decide the form and the chain.
Which company holds which shares, and whether a KStG § 9 tax group is in scope at all.
Draft the constitution.
Articles for two or more shareholders, a declaration of establishment for one, either way as a notarial deed under GmbHG § 4.
Pay in the capital.
The GmbHG § 10 Abs. 3 bank confirmation goes to the court with the filing; a GmbH has a EUR 5,000 cash floor.
File at the Firmenbuch.
Signatures certified, enclosures complete. A defective filing draws a court order to remedy it (FBG § 17), not a refusal.
Register with the tax office.
The tax account opens and the minimum corporate income tax runs from the first full quarter.
File the beneficial owners.
A corporate shareholder ends the WiEReG § 6 Abs. 2 exemption, so the chain above is reported.
No statute sets a processing time for a Firmenbuch registration, so this page gives none. Where a company is needed sooner, there is a shelf company austria.
Austria · holding company · six formation steps
- 01 /
Decide the form and the chain
Which company holds which shares, and whether a tax group is in scope at all.
KStG § 9 - 02 /
Draft the constitution
Articles for two or more shareholders, a declaration of establishment for one, either way as a notarial deed.
GmbHG § 4 - 03 /
Pay in the capital
A GmbH has a EUR 5,000 cash floor, and the bank confirmation goes to the court with the filing.
GmbHG § 10 Abs. 1 and Abs. 3 - 04 /
File at the Firmenbuch
Signatures certified, enclosures complete. A defective filing draws a court order to remedy it, not a refusal.
FBG § 17No statutory processing deadline - 05 /
Register with the tax office
The tax account opens and the minimum corporate income tax runs from the first full quarter.
KStG § 24 Abs. 4 Z 1 - 06 /
File the beneficial owners
A corporate shareholder ends the exemption, so the chain above is reported.
WiEReG § 6 Abs. 2
Not sure which form the holding should take?
Send the shareholding chain as it stands and where you want it to end up. We name the form, the filings and the charges.
What the Austrian state charges, and what it costs to keep alive
Two costs the structure carries whatever it earns: the court fee once, the minimum corporate income tax every quarter.
| What | Amount | Where it comes from |
|---|---|---|
| Application fee, GmbH or FlexCo first registration | EUR 47 | GGG Tarifpost 10 Z I, Anm. 2, from 1 August 2026 |
| Registration fee, GmbH first registration | EUR 475 | GGG Tarifpost 10 Z I, Anm. 9, from 1 August 2026 |
| GmbH first registration, total | EUR 522 | the two lines above, added |
| Application fee: an AG, an SE, a branch of an Annex I company wherever seated, and a branch of any entity seated outside the EU | EUR 130 | GGG Tarifpost 10 Z I, Anm. 3 |
| Registration fee, AG or SE | EUR 780 | GGG Tarifpost 10 Z I, Anm. 8 |
| AG first registration, total | EUR 910 | the two lines above, added |
| Later amendment of the articles | EUR 70 | GGG Tarifpost 10 Z I, Anm. 15 |
| Capital increase or reduction | EUR 222 | GGG Tarifpost 10 Z I, Anm. 12 |
| Filing on paper instead of electronically | EUR 24 | GGG Tarifpost 10, Anm. 1 |
| Minimum corporate income tax, GmbH or FlexCo | EUR 125 a quarter, EUR 500 a year | KStG § 24 Abs. 4 Z 1 |
| Minimum corporate income tax, AG | EUR 875 a quarter, EUR 3,500 a year | KStG § 24 Abs. 4 Z 1 |
Every Firmenbuch amount is GGG Tarifpost 10, in force from 1 October 2026, raised by BGBl. II Nr. 227/2026 from 1 August 2026. EUR 522 and EUR 910 are sums of two quoted lines. The minimum tax formula and its credit are on austria corporate tax; the first-years reduction, KStG § 24 Abs. 4 Z 3, is repealed (BGBl. I Nr. 200/2023).
What the Austrian tax rules give a holding
The dividend is not taxed twice.
Profit shares from a holding in an Austrian corporation are exempt under KStG § 10 Abs. 1, with no minimum holding and no holding period.
A foreign subsidiary comes with conditions.
KStG § 10 Abs. 1 Z 5 to Z 7 and Abs. 2 set them, and § 10a switches the exemption off for low-taxed passive structures. The figures are on austria corporate tax.
Only a foreign participation is sold tax free.
KStG § 10 Abs. 3 leaves gains, losses and value changes out of account for an internationale Schachtelbeteiligung within Abs. 2. A gain on an Austrian subsidiary is not covered.
Losses travel only inside a group.
KStG § 9 lets linked companies pool results, on conditions the corporate tax page sets out.
Financing the purchase: what is deductible and what is not
Austria lets a holding deduct interest on money borrowed to buy shares whose dividends are exempt. Four provisions limit it.
| Rule | What it does | Paragraph |
|---|---|---|
| Acquisition interest is a business expense | Interest connected with the debt financing of an acquisition of capital shares within KStG § 10, so far as the shares are business assets | KStG § 11 Abs. 1 Z 4 |
| But not the costs around it | Money-procurement and ancillary costs may not be deducted, and neither may anything within § 12 Abs. 1 Z 9 or Z 10 | KStG § 11 Abs. 1 Z 4, second sentence |
| Bought from inside the group | No deduction where the shares were acquired, directly or indirectly, from a group company or from a shareholder exercising a controlling influence. Capital increases and contributions connected with such a purchase are caught too | KStG § 12 Abs. 1 Z 9 |
| Recipient taxed below 15 percent | No deduction for interest or royalties within EStG § 99a Abs. 1 paid to a group recipient that bears no tax, or an actual burden below 15 percent, by exemption, rate, relief or refund | KStG § 12 Abs. 1 Z 10 |
| The cost of exempt income | Expenses outside § 11 Abs. 1 may not be deducted so far as they stand in a direct economic connection with tax-neutral increases in assets and income | KStG § 12 Abs. 2 |
| Write-downs caused by distributions | A write-down to the lower going-concern value, or a loss on disposal, is deductible only so far as it is shown not to be caused by distributions out of the subsidiary | KStG § 12 Abs. 3 Z 1 |
| Deductible write-downs are spread | Over the year of the loss and the following six, one seventh each | KStG § 12 Abs. 3 Z 2 |
| The interest limitation | An interest surplus is deductible up to 30 percent of tax EBITDA, and in any event up to EUR 3 million per assessment period | KStG § 12a Abs. 1 |
| Who is outside it | A corporation that is not fully consolidated, has no associated enterprise within § 10a Abs. 4 Z 2 and has no foreign permanent establishment. All three must hold | KStG § 12a Abs. 2 |
| The equity escape | The whole surplus is deductible where the corporation is fully consolidated and its equity ratio equals the group's, or is up to 2 percentage points below it | KStG § 12a Abs. 5 |
KStG § 11, from 20 July 2022 (BGBl. I Nr. 108/2022), KStG § 12, from 1 January 2026, KStG § 12a, the Zinsschranke, from 1 January 2021 (BGBl. I Nr. 3/2021). A disallowed surplus carries forward on application (§ 12a Abs. 6 Z 1).
Austria · acquisition interest · one grant, three restrictions
Acquisition interest is deductible
Interest connected with the debt financing of an acquisition of capital shares within KStG § 10 is a business expense, although the dividends those shares produce are exempt.
KStG § 11 Abs. 1 Z 4
↓then three provisions restrict it
- 01 · takes it back
Bought inside the group
No deduction where the shares were acquired, directly or indirectly, from a group company or from a shareholder exercising a controlling influence.
KStG § 12 Abs. 1 Z 9
- 02 · takes it back
Recipient taxed below 15 percent
No deduction for interest or royalties paid to a group recipient bearing no tax, or an actual burden below 15 percent, by exemption, rate, relief or refund.
KStG § 12 Abs. 1 Z 10
- 03 · takes it back
Surplus above 30 percent of EBITDA
An interest surplus is deductible up to 30 percent of tax EBITDA, and in any event up to EUR 3 million per assessment period.
KStG § 12a Abs. 1
Before the loan documents are signed
Send the financing as planned: who lends, who buys the shares from whom, where the lender sits. Where an answer is reserved to a licensed Steuerberater, we say so.
Dividends leaving Austria
Nothing is deducted at one tenth.
EStG § 94 Z 2 stops the capital yields deduction on distributions from an AG, a GmbH, a Flexible Kapitalgesellschaft or a cooperative where the recipient corporation holds at least one tenth of the nominal capital.
A foreign parent adds a year.
The same applies to a foreign corporation meeting the Annex 2 and Article 2 conditions of Directive 2011/96/EU, where the holding has lasted an uninterrupted year.
Otherwise it is deducted and reclaimed.
KStG § 21 Abs. 1 Z 1a repays it on application to an EU or EEA resident so far as it cannot be credited at home. The same paragraph has a second limb, read at source on 2026-09-17: the repayment is also available to a limited taxpayer resident in any other state with which comprehensive administrative assistance exists, where that taxpayer holds less than one tenth of the withholding agent's capital. Rates belong to Withholding Tax in Austria (KESt).
What the seat has to be, and what treaty relief asks for
Austria asks a holding for substance, not confidentiality, and its own statutes do the asking.
The seat is a place, not an address.
GmbHG § 5 Abs. 2 fixes it where the company has an operation, its management or its administration. Departing needs an important reason.
Tax follows where the decisions are made.
BAO § 27 Abs. 2 puts the place of management where the centre of the commercial top management sits. The register entry does not settle it.
Relief at source asks for staff and premises.
Where the recipient is a legal person, DBA-Entlastungsverordnung § 3 Abs. 1 requires a declaration of activity beyond asset management, own employed staff and own premises, on top of the § 2 residence certificate.
And it is refused outright in six cases.
§ 5 Abs. 1 of the same regulation (BGBl. II Nr. 318/2022, from 1 September 2022) bars relief at source on insufficient documentation (Z 1); where the payer knows, or would know using the care of a prudent merchant, that the declarations are wrong (Z 2); where a payment for an activity under EStG § 99 Abs. 1 Z 1 does not go to the person who performed it (Z 3); where the recipient is a foreign foundation, trust or fund (Z 5); where a legal person's effective management is outside its state of incorporation (Z 6); and where the capital yields are paid out by a credit institution at maturity or on a sale of securities (Z 7), which is the ordinary custodied dividend. Z 4 was repealed by BGBl. II Nr. 318/2022, so six of the seven numbers are live. Corrected 2026-09-17: this passage previously named four.
How this page is kept accurate
Every figure here names its paragraph, its Bundesgesetzblatt reference where it has one, and the date it took effect. Where a question is reserved to a licensed Steuerberater under WTBG 2017 § 2 Abs. 1, this page states the rule and stops. No processing times: no statute sets one. Updated 17 September 2026.
Related services
how an Austrian private foundation works The other way to hold assets here. No owner, and it may not manage a trading company (PSG § 1 Abs. 2 Z 2).
austria corporate tax The rate, the participation exemption in full, group taxation, the minimum tax by form.
gmbh in austria The form most Austrian holdings take, from the notarial deed to the first filings.
Frequently asked questions
Is there a special Austrian holding company, or a holding licence?
No. The main book of the Firmenbuch is kept for thirteen classes of entity and a holding company is not one of them (FBG § 2, in force from 1 January 2024). A GmbH may be formed for any legally permissible purpose (GmbHG § 1 Abs. 1), so an Austrian holding is an ordinary company that holds participations.
What does an Austrian holding company actually do?
It holds the shares in the operating companies, receives their dividends, carries the acquisition financing and can lead a tax group under KStG § 9. It stays an ordinary company while it does so: Book III of the UGB applies to every corporation without a turnover threshold (UGB § 189 Abs. 1 Z 1).
Should the holding be a GmbH, a FlexCo or an AG?
The statutory differences are capital, organs and formality. A GmbH or a FlexCo needs EUR 10,000 of share capital (GmbHG § 6 Abs. 1, from 1 January 2024) and an AG needs EUR 70,000 (AktG § 7). Registering a GmbH costs EUR 522 in court fees from 1 August 2026 and an AG EUR 910.
Are dividends from my Austrian subsidiary taxed again at the holding?
No. Profit shares of any kind from a holding in an Austrian corporation or cooperative are exempt from corporate income tax under KStG § 10 Abs. 1, with no minimum holding and no holding period. Foreign dividends are exempt on the conditions in Abs. 1 Z 5 to Z 7 and Abs. 2. The figures are on austria corporate tax.
Can an Austrian holding company sell a subsidiary without tax?
Only a foreign one. KStG § 10 Abs. 3 leaves gains, losses and other changes in value out of account for an internationale Schachtelbeteiligung within the meaning of Abs. 2, which is at least one tenth held for an uninterrupted year. A gain on an Austrian subsidiary is not reached by it.
Can I own and run an Austrian holding company from abroad?
You can own it from anywhere. The seat is the constraint. GmbHG § 5 Abs. 2 requires it to be fixed where the company has an operation, where its management is located or where its administration is conducted, and departing from that needs an important reason. For tax, BAO § 27 Abs. 2 follows the centre of commercial top management.
What does the Austrian state charge to register a holding company?
For a GmbH, EUR 47 to apply and EUR 475 to register, so EUR 522, under Gerichtsgebührengesetz Tarifpost 10 Z I, Anm. 2 and Anm. 9, at the amounts in force from 1 August 2026 (BGBl. II Nr. 227/2026). For an AG or an SE, EUR 130 and EUR 780, so EUR 910. A paper filing adds EUR 24.
What does a holding company cost to keep alive if it earns nothing?
The minimum corporate income tax. KStG § 24 Abs. 4 Z 1 charges 5 percent of one quarter of the statutory minimum capital for every full calendar quarter of unlimited liability: EUR 125 a quarter and EUR 500 a year for a GmbH or FlexCo, EUR 875 and EUR 3,500 for an AG. The first-years reduction was repealed by BGBl. I Nr. 200/2023.
Can the holding deduct the interest on the loan it used to buy the shares?
KStG § 11 Abs. 1 Z 4 treats interest connected with the debt financing of an acquisition of capital shares within KStG § 10 as a business expense, although the dividends those shares produce are exempt. The same provision excludes money-procurement and ancillary costs, § 12 Abs. 1 Z 9 removes the deduction for an intra-group purchase, and § 12a caps the surplus.
What is the dividend tax rate in Austria when the profit leaves the holding?
The rate depends on who receives the distribution and it is the subject of Withholding Tax in Austria (KESt), not of this page. What belongs here is the exemption: EStG § 94 Z 2 stops the deduction where the recipient corporation holds at least one tenth of the nominal capital, directly or indirectly.
What happens if my parent company does not qualify for the exemption?
The tax is deducted and relief is claimed afterwards. KStG § 21 Abs. 1 Z 1a requires capital yields tax to be repaid on application to an EU or EEA resident so far as it cannot be credited at home under a treaty, and the taxpayer has to prove that. EStG § 94 Z 2 routes directive relief the same way where the Finance Minister has ordered withholding.
Will my name appear on a public Austrian register?
The shareholders of a GmbH are recorded in the Firmenbuch. The beneficial-owner register is a separate filing, and the WiEReG § 6 Abs. 2 exemption runs only while every shareholder is a natural person. A holding structure has a company in the chain, so the beneficial owners are reported.
Start your Austrian holding structure
Send the companies you hold today, the ones you want above them, and where the money comes from. You get the form, the filings, the charges and where a licensed adviser takes over.