On 25 January 2019, Austria published an ordinance in the Official Gazette on passive income of low-taxed entities. The ordinance is in relation to Austria's new controlled foreign company (CFC) rules, which generally provide for the inclusion of specified passive income of a CFC where the passive income represents more than a third of the CFC's total income and the CFC is low-taxed, meaning the actual tax burden does not exceed 12.5% ({News-2018-07-19/A/2-previous coverage}). The ordinance includes rules on determining whether a CFC is low-taxed, rules for the substantial economic activity exemption, and other matters. The ordinance and the CFC...