On October 8th, 2021, the OECD/G20 Inclusive Framework on BEPS issued its “Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy", outlining the agreement on BEPS 2.0 to ensure that multinational enterprises will be subject to a minimum effective tax rate of 15 % from 2023. A new income inclusion rule will safeguard this minimum tax rate. Only a few years ago, Austria introduced CFC legislation because of BEPS 1.0 and the EU Anti-Tax Avoidance Directive (ATAD). In this article, Kasper Dziurdź compares the income inclusion rule to the Austrian CFC rule and outlines the key differences as well as the expected impact.
