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Trusts & Trustees Advance Access originally published online on May 25, 2009
Trusts & Trustees 2009 15(5):316-321; doi:10.1093/tandt/ttp053
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© The Author (2009). Published by Oxford University Press. All rights reserved.

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

Friedrich Schwank*

*Dr. Friedrich Schwank, Law Offices Dr F. Schwank, Stock Exchange Building, Wipplingerstrasse 34A-1010 Vienna, Austria. Tel: + 43 1 533 57 04; Fax: +43 1 533 57 06; Email: offices{at}schwank.com; Website: www.schwank.com

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.


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