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Subject: the core business of the foreign company ...predominantly and sustainably is... law Information about the corporate income tax rate applicable to the foreign subsidiary. The reason why we ask for this information is that the Austrian Corporate Income Tax law applies the “credit regime” rather than the participation exemption to certain types of foreign participations. Foreign participations fall in this category if
- the core business of the foreign company (directly or indirectly) predominantly and sustainably is the generation of certain kinds of passive income (ie either interest income, income derived from the leasing or letting of movable tangible or intangible assets or income from the disposal of subsidiaries)
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