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Austria Updates Transfer Pricing Guidelines

25 March 2025

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Approved Changes

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Austria

Austria's Ministry of Finance has published the Transfer Pricing Guidelines 2021 - Maintenance Decree 2025. The maintenance decree provides various updates, including in relation to the 2022 edition of the OECD Transfer Pricing Guidelines. The main updates include the following: All references to the OECD Transfer Pricing Guidelines are adapted to the 2022 version of the OECD Transfer Pricing Guidelines; Clarifications regarding the cost basis for applying a cost-based method for transitory items; Clarifications regarding the fundamental need for comparability of accounting standards in the context of the comparability analysis; Clarifications regarding the term shareholder activities and interaction with the...