The new regulation on controlled foreign corporation will lead to a rethinking in Austria. A comparable legal situation does not currently exist and has not been desired for years. By publishing the international measures of the OECD-BEPS action plan and subse-quently the binding Anti-Tax Avoidance Directive in the EU, the member states will have to implement a certain minimum standard of protection against base erosion and profit shifting in their legislation. In the course of the Annual Tax Act 2018 Austria will adapt their change-of-method rule under, their abuse regulation and introduce a CFC-rule with § 10a KStG for a directive-compliant implementation. Many parts of the regu-lation is identical at all three levels, but granted options to choose the preferred model and the permitted tightening of the standard at national level allow immense scope. This not only leads to different levels of intensity in the user states and increasing administra-tive costs, but also has a particular effect against the original intention of simplifying international tax law. The current version of the draft of § 10a KStG, which will regu-late corporate foreign control in the future, still contains individual weaknesses such as an excessively restrictive setting in the determination of the limit for low taxation of 12.5%, the lack of consideration of shareholdings below 5% and a missing indication of the possibility of a tax carry-forward. The actual relevance of this new regulation is very difficult to assess due to the lack of empirical data, especially for the Austrian region, which will only become apparent after a certain period of application and observation.