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On 25 September 2014, the Austrian Ministry of Finance published a list of jurisdictions with which Austria has concluded a comprehensive mutual administrative assistance agreement as of 1 January 2015. The list is of particular importance in regard to Austria's group taxation regime, which includes the requirement that companies located in third jurisdictions may only be part of an Austrian tax group when the company is an EU Member State or in a jurisdiction with which Austria has an administrative assistance agreement. A similar rule also applies for participation exemption for portfolio dividends derived from companies resident in third countries....