Adózás Ausztriában

Einkommensteuer / Személyi jövedelemadó Magánszemélyek Ausztriában adóköteles jövedelmük után személyi jövedelemadót fizetnek. A személyi társaságok nyeresége illetve vesztesége nem társasági szinten adóköteles, hanem a társaság egyes tagjaira jutó jövedelem a társaság adott tagjának üzemi (vállalkozási) tevékenységből származó jövedelmét képezi, mely után a tag személyi jövedelemadót fizet. Az adóköteles jövedelmet sávosan progresszív kulcsokkal adóztatják. Az Ausztriában korlátlanul adóköteles (osztrák rezidens) személyek számára 2016. január 1-től a következő adótételek érvényesek: Személyi jövedelemadó (€-ban):
11.000 –ig 0% 11.000-től 18.000-ig 25% 18.000-től 31.000-ig 35% 31.000-től 60.000-ig 42% 60.000 -től 90.000-ig 48% 90.000 -től 1 Millióig :50% 1 Millió felett 55%.
Az adómentes sáv az Ausztriában személyi jövedelemadó szempontjából korlátozott adókötelezettség alá eső (külföldi illetőséggel bíró) személyek esetében 2. 000 € évente. Egy Ausztriában korlátlanul adóköteles személynek adóbevallást kell benyújtania, ha az adóhatóság erre felszólítja, ha vállalkozási jellegű jövedelmet szerzett, vagy ha jövedelme meghalad egy bizonyos értékhatárt (pl. ha nincs béradó köteles jövedelme, akkor ez 10.900 €). A fizetendő jövedelemadó összegét az adóhivatal a bevallott jövedelmek alapján számolja ki és határozat útján írja elő. A jövedelemadó két különleges beszedési formája a béradó valamint a tőkehozadéki adó. Tőkehozadéki adó (Kapitalertragsteuer) Egyes belföldi tőkejövedelmek után a kifizető köteles a jövedelemadót az ún. tőkehozadéki adó formájában levonni. A tőkehozadéki adó mértéke 35%. A tőkehozadéki adó alá esnek: • Belföldi tőkejövedelmek (pl. belföldi tőketársaság által fizetendő osztalékok, egyéb nyereségrészesedések, csendes társ jövedelme, banki kamatok stb.) • Belföldön kifizetett értékpapír jövedelmek. • Belföldi tőketársaságok bizonyos tőkehozadéki adó köteles tőkejövedelmei (osztalékok, kamatok stb.) esetén, ha legalább egy 25%-os közvetlen részesedés áll fenn az azt fizető társaságban. • Nem ausztriai illetőségűek kamatjövedelme adómentes, ha a hitelintézetnek igazolják származásukat es külföldi lakóhelyüket. Egyes esetekben, elsősorban természetes személyek kamat és osztalékjövedelménél tőkehozadéki adó levonása után ezekre a jövedelmekre további személyi jövedelemadó fizetési kötelezettség nem keletkezik. A külföldről származó tőkejövedelmek hátrányos megkülönböztetésének elkerülése ezek – bizonyos esetekben – egy a tőkehozadéki adóval összehasonlítható különleges 35%-os adókulcs alá esnek (egy esetlegesen akár 50%-os progresszív személyi jövedelemadó kulccsal szemben). Társasági adó (Körperschaftsteuer) A társasági adó a jogi személyek jövedelemadója. Jogi személyiség híján a személyi társaságok (OHG, OG, KG) nem alanyai ennek a jövedelemadónak. A társasági adó alanyai: • A magánjog jogi személyei mint például a tőketársaságok (GmbH, AG, Fióktelep “Zweigniederlassung”) • Szövetkezetek • A közjogi társaságok üzleti jellegű üzemei, vállalkozásai • Nem jogképes egyesülések, alapítványok és más célvagyonok A társasági adó mértéke Az osztrák társasági adó mértéke 2005-től egységesen 25%. Korlátlan adókötelezett tőketársaságoknak minimál adót kell fizetniük, melynek mértéke az adott társasági forma törvényes minimál tőkéjének 5%-a. Ez éves szinten 1.750 € GmbH esetében és 3.500 € AG esetében. Abban az esetben, ha az előirt társasági adó egy évre kevesebb, mint a befizetett minimál adó, a különbözet a következő évek társasági adófizetési kötelezettségével elszámolható. Részesedésből szerzett jövedelmek Az osztrák tőketársaságok más belföldi tőketársaságban, valamint szövetkezetekben tartott részesedéséből származó nyereség részesedésre (osztalékra) általános adómentesség érvényes. Az adómentesség mind közvetlen, mind közvetett részesedésekből származó ilyen jövedelmekre érvényes. A kedvezmény nem vonatkozik a belföldi részesedések (üzletrészek és részvények) értékesítésére. Külföldi tőketársaságokban tartott részesedésekből származó jövedelmekre az ún. “nemzetközi részesedési kedvezmény” szabálya érvényes. E szerint az osztrák “holding cég” adómentessége csak akkor keletkezik, ha az adózó a külföldi vállalatban (mely osztrák tőketársasághoz hasonló vagy az EU irányelv szerint társaságnak minősül) igazolhatóan legalább 1 éve megszakítás nélkül minimum 10%-al részesedett. Az ilyen részesedés értékesítéséből származó nyereség szintén adómentes. 2004-töl opciós jog keretében a részesedéssel kapcsolatos nyereségek és veszteségek, egyéb értékváltozások vagy egységesen adómentesek vagy egységesen adókötelesek. Az opció nem visszavonható, viszont annak keretében a részesedés esetleges értékvesztése levonhatóvá válik. Általános forgalmi adó (Umsatzsteuer) Az általános forgalmi adó (áfa) hatálya a következő értékesítésekre terjed ki: • Termékek és egyéb szolgáltatások, melyeket egy vállalkozó belföldön, térítés ellenében a vállalkozása keretében értékesít • A belföldi saját fogyasztás • A termékimport harmadik országból (behozatali forgalmi adó) EU-n belülről történő termékbeszerzés belföldön (uniós behozatali forgalmi adó) Az általános forgalmi adó alanya a vállalkozó (“Unternehmer”). Vállalkozónak számit, aki vállalkozási vagy egyéb szakmai jellegű tevékenységet önállóan gyakorol. Adómentességek Az általános forgalmi adómentességek 2 csoportját különbözteti meg az osztrák adójog: • valódi általános forgalmi adómentesség (echte Steuerbefreiung) • hamis általános forgalmi adómentesség (unechte Steuerbefreiung) Valódi általános forgalmi adómentesség alá azok a bevételek (termékértékesítések és szolgáltatásnyújtások) esnek, melyeknél az előzetesen felszámított általános forgalmi adó levonható. Ilyenek pl. az export harmadik országba, a belföldön végzett, de harmadik országba kiszállított bérmunka, tengeri hajózás és légiközlekedés stb. Hamis általános forgalmi adómentesség alá azok a bevételek (termékértékesítések és szolgáltatásnyújtások) esnek, melyeknél az előzetesen felszámított általános forgalmi adó nem levonható. Ilyenek pl. mindazok a termékbeszerzések és igénybe vett szolgáltatások, melyek áfa mentes bevételekkel függnek össze, mint pl. ingatlanforgalmazás, játéknyeremények, ingatlan bérbeadása (kivéve egyes bérbeadásokat, mint pl. lakáscélú bérbeadás) magániskolák bevételei. A speciális áfa-mentesség érvényes belföldi kisvállalatokra is, melyek éves árbevétele nem több, mint 22.000 €. A 22.000 € határ túllépésére a kisvállalkozásoknak öt év alatt egyszer lehetőségük van, ennek a mértéke azonban nem haladhatja meg a 15%-ot. A kisvállalatok lemondhatnak az adómentességről és adókötelesnek tekinthetik forgalmukat. Általános forgalmi adó kulcsok: Ausztriában 2 általános forgalmi adókulcs van érvényben: • 20% normál adókulcs • 10% kedvezményes adókulcs (pl. élelmiszerek, kultúrcikkek, lakáscélú bérbeadás, személyszállítás stb.) Kivételes esetekben 2 további adókulcs alkalmazható: 12% csak saját előállítású borra; 16% a vámszabad területnek számító jungholzi és mittelbergi illetőségű vállalkozók e területre vonatkozó forgalma esetében.

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