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Analyse der Auswirkung der BEPS-RL auf Zinsverlagerungen österreichischer Kapitalgesellschaften / eingereicht von: Nico Dietz, B.Sc.
AuthorDietz, Nico
Thesis advisorTreisch, Corinna
PublishedInnsbruck, September 2018
Descriptionvi, 63 Blätter : Illustrationen
Institutional NoteUniversität Innsbruck, Masterarbeit, 2018
Date of SubmissionSeptember 2018
Document typeMaster Thesis
Keywords (DE)Zinsschranke / Anti-BEPS-Richtlinie / Zinsabzugsbeschränkung
Keywords (EN)interest barrier / Anti-BEPS-directive / limitation of interest deduction
Keywords (GND)Österreich / Kapitalgesellschaft / Zinsschranke / OECD / Base Erosion and Profit Shifting Project
URNurn:nbn:at:at-ubi:1-27155 Persistent Identifier (URN)
 The work is publicly available
Analyse der Auswirkung der BEPS-RL auf Zinsverlagerungen österreichischer Kapitalgesellschaften [0.78 mb]
Abstract (English)

On 07/12/16, the European Union (EU) implemented the Anti-Tax-Avoidence-directive also called Anti-BEPS-directive. Art. 4 of this directive contains a general interest barrier. Through this interest barrier it could happen, that not all interests can be taxable recognised. This directive has to be adopted from all the union members into their national law by 01/01/19. Thus, exploring this in-terest barrier impact on Austrian corporations was necessary and useful, be-cause the interest barrier could have economically effects on the corporations. Those impacts were analysed through an explorative case-study approach, which wasn`t applied by the existing research so far. Basically, a theoretical sampling was used in order to find industrial Austrian corporations, most prob-ably handling with this interest barrier. This study should give answers, if and in which economically situations the interest barrier influence the after taxes results of the Austrian corporations. For this qualitative and quantitative data of the voestalpine and Lenzing groups were explored and analysed by applying single case-studies. The quantitative data were analysed through a model that was constructed to determine the after tax results. The findings, show us that the economically consequences for industrial concerns aren't that high as the interest-barrier impacts the after tax results mainly in poor economically peri-ods by limiting the interest deduction. In those periods, the after tax results de-creased while the tax payments increased. Additionally, the findings can attest that the interest-carryforward have an exculpatory effect and through that no long-term economically consequences rise-up on the corporations.

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