Austria to enact new interest limitation rule in accordance with EU ATAD as of 2021

In 2018, Austria did not adopt the regulations of the interest limitation rule under the European Union (EU) Anti-Tax Avoidance Directive¹ (ATAD) into national law by 31 December, as required by the Directive. The Austrian Government believed that the domestic regulations of Section 12/1/9 of the Corporate Income Tax Act (CITA) (non-deductibility of interest paid on debt to refinance the acquisition of shares from affiliates) and Section 12/1/10 CITA (non-deductibility of interest…