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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Austria: Underlying Tax

Documents needed to support the underlying tax claim

The accounts and the relevant page of the tax assessment (Bescheid) showing the amount of corporation tax (Korperschaftsteuer) chargeable (Abgabenschuld).


Relevant profits are reduced by transfers to:

  • Legal reserve (gesetzliche Rucklage) for corporations (AGs) only until it reaches 10% of the share capital

and relevant profits are reduced/increased by transfers to/from the following, which may be included in untaxed reserves (unversteuerter Rucklagen):

  • Indemnity reserve
  • Investment reserve
  • Investment deduction reserve.