Austria: private foundation--tax-planning strategies for international family offices

Abstract

In 2009, the Austrian private foundation is more attractive than ever as a means of international wealth and succession planning. The Austrian low entry tax of 2.5 per cent of the endowment, no gift or inheritance tax, and treaty protection for distributions to non-resident beneficiaries, gives the Austrian private foundation a lead amongst other structures aiming at making a profit. Its legal qualification as a corporate structure enables the Austrian private foundation to act as an ultimate holding vehicle, claim tax treaty protection and benefit from the international participation exemption for foreign dividends and capital gains.