According to recent reports, the Austrian parliament has approved amendments to the country's controlled foreign company (CFC) rules in order to avoid double taxation issues in relation to the Pillar 2 global minimum tax rules. In particular, amendments to § 10a of the Austrian Corporate Income Tax Act were approved to provide that any Qualified Domestic Minimum Top-up Tax (QDMTT) levied in the residence state of a CFC must be included in the effective tax rate (ETR) calculation for CFC purposes. Therefore, Austria's CFC rules will not apply if the foreign subsidiary of an Austrian parent company is subject to...