Holding companies and corporate groups

Whilst multinational companies are faced with an array of individual tax rules, the most innovative solutions can only be applied in a global approach. Improving a corporate group's effective tax rate involves cross-border issues such as: what is the optimal tax structure for the group? How should inter-company transfer prices be structured and documented? Which options provides the most attractive Austrian taxation for the group as a whole or the ability to exploit tax concessions using group structures?


Local und international

We work on a global basis with the Nexia consulting network on questions like these, allowing us to provide the latest information to our international clients.

We inform you about the impact of recent legal judgments and legislation within the EU. Our consultants are accustomed to working in an international environment and have a clear understanding of international tax law both within and outside Europe.

Services at a glance

  • Group tax planning
  • Holding structures
  • Choosing the optimal holding company location
  • Tax structuring of outward investments
  • Tax structuring of inward investments in Austria
  • Advising and issuing expert opinions when creating tax compliance systems
  • Creating compliance packages for the UBO register
  • Cross-border restructuring
  • Optimal structure of business transactions between affiliated companies
  • Transfer pricing and documentation
  • Transfer pricing models
  • Defending your transfer pricing during tax audits
  • Foreign loss utilisation under group taxation
  • Tax optimisation through permanent establishments
  • Cross-border financing
  • Withholding tax optimisation
  • International assignments
  • Communication with financial authorities (tax inquiries, EAS and advanced ruling inquiries, mutual agreement procedures)
  • Application and interpretation of double taxation agreements

Your contacts

Erik Malle
Erik Malle
Managing Partner | Certified Public Accountant, Tax Advisor
Philip Stagel
Philip Stagel
Managing Partner | Tax Advisor
Andreas Kauba
Andreas Kauba
Managing Partner | Certified Public Accountant, Tax Advisor

Each sector is unique. And we advise you accordingly.