DT2754 - Austria: Dividends

The Austrian tax deducted from dividends at the agreement rate of 15 per cent (or 5 per cent where the beneficial owner of the dividends is a United Kingdom resident company controlling directly or indirectly 25 per cent of the voting power in the company paying the dividend) qualifies for credit as a direct tax (see DT950(c)). The reductions to the above rates are not given if the dividends are effectively connected with (see DT214 fifth sub- para.) a business carried on by the United Kingdom resident recipient through a permanent establishment in Austria.

The agreement does not provide for credit relief for underlying tax (see DT950(d)) and where appropriate unilateral relief for underlying tax should be given to a company in respect of dividends paid by an Austrian company (see DT987).

See DT956 for information on relief for Austrian tax where dividends are paid on or after 1 January 1995 to a company resident in the United Kingdom which holds at least 25 per cent of the capital of the company paying the dividend.